Department of Health Seal

TGM for the Implementation of the Hawai'i State Contingency Plan
Section 16.0
REMEDIAL ACTIONS

16.0 REMEDIAL 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. The HDOH Hazard Evaluation and Emergency Response Office (HEER Office) may decide remedial action is appropriate for a complex release site, if site-specific data may be difficult to obtain, or when additional scrutiny, review, and feedback by third parties could be beneficial.

For example, the HEER Office may decide on a remedial action approach under the following conditions:

  • Groundwater contamination, especially in a drinking water aquifer
  • Soil contamination with a direct migration pathway to a nearby drinking water aquifer
  • Contamination (soil or groundwater) crosses property boundaries
  • Contaminants are present at high levels or consist of complex mixtures
  • Soil contamination beyond the reach of conventional excavation equipment, and still presents exposure pathways for identified environmental hazards
  • Site is adjacent to current or potential sensitive communities/residences (such as for schools, day care centers, or public recreational areas) and/or may impact sensitive/protected species

The voluntary Fast Track Cleanup Program (see Section 15), which provides an option for a more streamlined process for site investigations and cleanups, is intended for sites where removal actions, rather than remedial actions, will occur. Sites in the Voluntary Response Program (VRP) (see Section 1.3.2.5 and Section 20.3) for additional information on the VRP) are required to follow the public participation steps of the remedial action process whether the cleanup response is conducted as a removal or a remedial action.

The additional documentation and review steps provided by the remedial action process (see Section 2, Figure 2-2) are necessary to address the more complex or sensitive nature of these cleanups. Remedial actions may include physical, biological, or chemical methods to isolate or transform the contamination, as well as measures to protect human health and the environment.

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 assessment and/or response action, as appropriate under Hawai`i Environmental Response Law (HRS 128D). If necessary, the HEER Office may enter into consent agreements or issue orders to require identified responsible parties to conduct any necessary assessments or response actions.

Remedial response actions are intended to:

  • Eliminate, reduce, prevent, minimize, mitigate, or control risks to public health or the environment
  • Provide for efficient, cost effective, and reliable long-term cleanup remedies which protect human health and the environment

A remedial action consists of four broad phases:

  • Remedial investigation
  • Remedial alternatives analysis
  • Remedy selection
  • Remedy implementation