HSRA Notification 391-3-19-.04 Frequently Asked Questions
What is a HSRA notification?
When a regulated substance is discovered in soil or groundwater, the property owner must determine if, pursuant to the Rules for Hazardous Site Response, notification of the release to the Georgia Environmental Protection Division (EPD) is required. If notification to EPD is required, then a release notification/reporting form must be completed and submitted in electronic format with supporting documentation (e.g., current U.S. Geological Survey topographic map, analytical data, Phase 2 report, etc.) to:
Response and Remediation Program
Georgia Environmental Protection Division
2 Martin Luther King, Jr. Dr. SE
Suite 1054, East Tower
Atlanta, GA 30334
The release notification can be downloaded as an Adobe PDF or a fillable Microsoft Word form . Guidelines for electronic submittal can be found here Document Submittal Form.
Who needs to notify?
Any owner of real property where the release was discovered.
When do I need to notify the State of a release?
You need to notify the State when a regulated substance has been detected in groundwater above the concentrations listed in Appendix III: Table 1 Groundwater Criteria in the Georgia Rules for Hazardous Site Response. If the detected regulated substance is not listed in Appendix III: Table 1, then any detection in groundwater above the naturally occurring background concentration requires notification. Notification is also required if a regulated substance has been detected in soil above the Notification Concentration listed in Appendix I of the Georgia Rules for Hazardous Site Response.
Notification is also required for other releases, including discarded or abandoned regulated substance in barrels, drums, tanks or other storage or transportation vessels; in process units; or in waste management units that are not under a permit or are otherwise already regulated under the Georgia Hazardous Waste Management Act.
Certain releases are excluded from notifications, such as releases that are cleaned up within 30 days of discovery; releases of petroleum-based fuel, lubricant or hydraulic fluid; and releases regulated under the Georgia Underground Storage Tank Act (refer to “Exclusions” for complete list).
When do I need to notify?
You are required to notify EPD of the release within 30 days of the discovery of the release.
What happens after I submit a notification?
Using the information in the notification, and any additional information available to EPD, EPD determines if a release above a reportable quantity has occurred. EPD does this by using the reportable quantities screening method (RQSM).
RQSM assigns numerical values to factors such as the toxicity, quantity, and physical state of the regulated substance released; how close the property is to nearby residents and drinking water wells; the degree to which the release is contained; the accessibility of the property; whether or not the release has resulted in exposure to nearby residents; and the presence of on-site sensitive environments.
RQSM uses a mathematical equation to combine the numerical values for these factors into a single score for soil or groundwater. If this score is above an established threshold number for either soil or groundwater, a release exceeding a reportable quantity has occurred and the property is recommended for placement on the Hazardous Site Inventory (HSI). EPD may also place a property on the HSI if the site otherwise poses a threat to human health or the environment.
The most up-to-date description of how EPD uses RQSM can be found in the document, " Guidance Manual for the Reportable Quantities Screening Method " dated February 10, 1994 and updated March 1994, January 2008 and April 2016.
When referencing this document, keep in mind the maximum contaminant levels (MCLs) may have changed. Please consult the latest MCLs listed in the Georgia Rules for Safe Drinking Water.
What are some common mistakes?
- Release notification/reporting form does not include all requested information. The form requires a list of attachments, including site summary, site map showing source and sample areas, and an original U.S. Geological Survey topographic map (1:24000) with the geographic center of the site clearly marked. Supporting documentation for the soil and groundwater release information tables (Part III and IV) include submittal of copies of analytical laboratory sheets.
- A thorough drinking water well survey was not done. Identification of the nearest drinking water well is critical for accurate scoring using RQSM. Often an assumption of “greater than three miles” for distance to nearest drinking water wells is made when a thorough search for wells has not been conducted.
- Inaccurate soil or groundwater sampling techniques. Listing on the HSI is dependent on both the type of regulated substance and the concentration of the regulated substance. Accurate sampling is critical to ensure proper scoring using RQSM (e.g., analysis of turbid groundwater samples may show false or elevated concentrations of metals).
- Reporting inaccurate information. As properties are developed and property changes are made that may affect a property’s scoring, it is important to note that EPD uses current information for the property. For example, if at the time of the site inspection, a property does not have a fence, EPD will score property access as “unlimited access.” A property that has been through the notification process, but not listed on the HSI, should re-notify when site changes occur that may effect the scoring.