Effective
Corrective
Action Plan
Preparation
REP Continuing Education
Course
Compliance Fund
Petroleum
Program
Remediation
REP Purpose
The purpose of the REP
designation is to better align
decision-making responsibility
between OPS, environmental
consultants and responsible
parties.
REP Logistics
• REPs will replace individual Listed Consultants
effective 1/1/18
• The REP designation is related to
reimbursement:
• Projects with an identified REP will be allowed
to seek reimbursement at the labor RCGs
• Projects without an identified REP will be
allowed to bill at a maximum of TLC 5.5
Continuing Education Purpose
To enhance the technical skills
and regulatory knowledge of
REPs through education and
training relevant to the
investigation, assessment and
remediation of petroleum
releases.
Continuing Education
Requirements
• 24 hours of REP Professional Development Hours
(PDHs) over a three year period beginning 1/1/18 are
required to recertify as a REP
• OPS will provide a mix of required and secondary
training modules
• A list of required classes will be posted by
10/31/17
• Externally-derived PDHs will make up the remaining
requirement and should reflect the program’s Basis
and Purpose statement
Ground Rules and Breaks
• Interactive – ask questions/discussion,
but be mindful of the time
• Be present and open-minded
• Turn off or silence cell phones
• There will be a morning break and a
lunch break
Continuing Education PDH
• This course will count as 5 PDH toward the CE
requirements
• Class is a required OPS training module
• Web-based class will be developed if unable to
attend in person
• A certificate of completion will be given at the
end of class and may be used to fulfill other
continuing education requirements as deemed
appropriate by the particular overseeing body
Continuing Education PDH
Why CAP Preparation?
• To identify the most technologically and
economically feasible remediation
technology that can be utilized to the
efficiently address the risks posed to human
health and environmental from a petroleum
release
• A CAP is required to be submitted within one
year from the suspected release date
Presentation Content
• Identify Contaminant Concerns
• Define Remedial Goals and
Objectives
• Identify Targeted Treatment Areas
• CAP Preparation Exercise
(Part 1)
• Evaluate/Screen Out/ Select
Remedial Technology
• Treatment Train/Combined
Remedy
• CAP Preparation Exercise
(Part 2)
• Performance
Metrics/Endpoints/Remedial
Milestones
• Groundwater Monitoring Network
and Sampling Frequency
• CAP Preparation Exercise
(Part 3)
• Summary/Questions
Training Objective
Clearly state OPS expectations on the important topic of
CAP guidance preparation through:
• Presenting the guidance
• Discussing the guidance
• Reinforcing the guidance concepts through classroom
exercises to enable a basis of selection for a remedial
technology(ies) to be presented
• Gaining an understanding that an approvable CAP
must detail each of the guidance concepts, otherwise
the plan is subject to denial
OPS CAP Guidance
Conceptual Site Model (CSM)
• Written and illustrative description of the release
• Based on all known environmental and site
information
• Dynamic process that continually incorporates new
information
• An adequately prepared CAP should align with site
components identified in the CSM
• Thoroughly developed CSMs aid in identifying
contaminant concerns
Identify
Contaminant Concerns
That Was Then...
…This is Now.
Comprised of four
distinct contaminant
phases to evaluate:
1. Sorbed (surficial,
subsurface soil)
2. Dissolved
(groundwater
ingestion)
3. Vapor (soil vapor and
groundwater to IA)
4. LNAPL
• Each phase may
present multiple
contaminant
concerns
• Clearly identified
contaminant
concerns lead to a
refined CSM with
well-defined
remedial objectives
and goals
Define Remedial Goals &
Objectives
Remedial Goal vs Remedial Objective
• Goal – a desired condition to be achieved
by a remedial strategy that indicates the
end of management for a specific
contaminant concern
• Objective – describes how a remediation
goal will be accomplished and must be
linked to the technology(ies) to be used
That Was Then…
• Cleanup to Tier 1, Tier
1A, or Tier 2
• Eliminate an exposure
pathway
• One remediation
technology often
proposed for cleanup
duration
• Goals were often
loosely defined –
seldom objective
…This Is Now.
• Desired condition (goal) to be achieved by a remedial
strategy (objective)
• Goals/Objectives are to be clearly defined based on
the identified contaminant concerns
• Goals/Objectives are critical for selecting and
implementing remedial technology(ies)
• Involves accounting for contaminant mass to be used
for performance metric and remedial endpoint
identification
• Be SMART
SMART?
Combined with performance metrics and remedial endpoints, an objective
becomes a SMART Objective
• Specific - Targeted treatment area and technology-specific endpoints
are clearly stated
• Measurable – Performance metrics that demonstrate progress towards
the endpoints
• Agreed Upon – Concerns, goals, objectives treatment areas metrics,
endpoints
• Realistic – Demonstrated ability to achieve objective
• Time-Based – Target date of remedial endpoint being achieved
Achieving a remedial endpoint does not necessarily mean that all
contaminant concerns have been eliminated
Identify Targeted Treatment
Areas
That Was Then…
• Define horizontal and vertical extent of contamination
• Area where contaminant concern(s) present seldom,
if ever, fully identified
• CAP approval was possible even without full
characterization and without full comprehension of
specific areas requiring treatment
…This Is Now.
• Specific areas where a contaminant concern(s) exists
• Assessment is key to identify contaminant distribution
– many HRSC tools are now available
• Detailed X-Sections – areas must be clearly depicted
for every remedial objective identified
• Identify not only accessible areas where concern(s)
exists, but also inaccessible areas
• Includes all completed exposure pathways
Quick Recap
• An adequately-prepared CAP should align with site components identified in the CSM
• Thoroughly developed CSMs aid in identifying contaminant concerns
• Clearly identified contaminant concerns lead to a refined CSM with well-defined remedial objectives and goals
• Remedial objectives & goals are critical for selecting and implementing remedial technology(ies) and need to be SMART
• Targeted treatment areas are specific areas where a contaminant concern(s) exists and need to be clearly depicted for every identified remedial objective
CAP Preparation Exercise
Part 1
Identify Contaminant Concerns,
Remedial Objectives and
Targeted Treatment Areas
CAP Preparation Exercises
• Part 1: Identify contaminant concerns, define
remedial objectives, and identify targeted
treatment areas
• Part 2: Evaluate, screen out, and select
remedial technologies for treatment
train/combined remedy
• Part 3: Establish performance metrics, remedial
milestones, and remedial endpoints
CAP Preparation Exercise Part 1
The exercise handout
includes the following:
• Cover page bullet list
summary of site assessment
results
• Site assessment data tables
for soil, LNAPL, groundwater,
and surface water
• GW elevation map, geologic
cross sections, and a plume
map showing LNAPL and
dissolved benzene
distribution
• CAP preparation table
Use the data tables
and figures to
complete the CAP
preparation table to
identify contaminant
concerns/remedial
objectives and
sketch the targeted
treatment areas on
the cross sections
and plume map
Surficial soils impacted above Tier I
RBSLs and surface is not covered by
an impervious material
Remove or reduce surficial soil impacts to below Tier I
RBSLs
Vadose zone soil impacted above Tier
I RBSLs and/or Tier II SSTLs and
groundwater is impacted or potentially
impacted
Remove or reduce vadose zone soil impacts to below Tier I
RBSLs and/or Tier II SSTLs
Vadose zone soil impacted below Tier
I RBSLs but groundwater impacted
above Tier I RBSLs
Remove or reduce vadose zone mass to address
contribution to groundwater
Smear zone or saturated soil
impacted and contributing to
groundwater contaminant migration
Reduce mass in smear zone and/or saturated soil to
address contribution to groundwater
LNAPL is migrating no
Terminate LNAPL mass migration by mass recovery or
mass control
LNAPL saturation is above residual
saturation (mobile) and transmissivity
is above the recoverable range Recover LNAPL to the MEP (transmissivity range)
LNAPL saturation is within the
residual saturation range and a
persistent source of dissolved phase
or vapor phase concerns Identify appropriate phase change technology or excavate
Reduce groundwater concentrations to below Tier I RBSLs
offsite and at POCs and to below Tier II SSTLs onsite
Remove or address source material contributing to
groundwater impact
Identify alternate water supply source
Modify the well intake
Reduce incoming groundwater concentrations to below Tier I
RBSLs
Engineered control to eliminate exposure to the receptor
Reduce concentrations to below Tier I RBSLs at property
boundary and offsite or Tier II SSTLs onsite
Implement measures to protect POEs from further impact
Evaluate and mitigate migration potential and exposure to
receptors
Evaluate and mitigate utility worker safety concerns
Remediate source (LNAPL, sorbed, dissolved) to eliminate
impacts
Engineered controls to prevent PVI
no
Vapor Petroleum vapor intrusion is impacting
a utility corridor and/or structure no
Sorbed
LNAPL
Dissolved
Impacted groundwater above Tier I
RBSLs offsite and/or SSTLs onsite
Domestic, irrigation, or water supply
well impacted or potentially impacted
above Tier I RBSLs no
Surficial water, springs, or sensitive
environment POEs impacted
Impacted groundwater has intercepted
a utility corridor
CORRECTIVE ACTION CONTAMINANT CONCERNS AND REMEDIAL OBJECTIVES IDENTIFICATION TABLE
Contaminant
Phase Contaminant Concern
Is this
concern
present? Remedial Objective
Treatment
Area
Identified?
Evaluate/Screen Out/Select
Remedial Technology(ies)
That Was Then…
…This Is Now.5 - Step Screening Process for Basis of Selection
Screen Based on Contaminant Concerns &
Remedial Objective(s)
Screen Based on Site Geologic Factors
Prioritize Additional Evaluation Factors and Perform Comparative
Analysis
Identify Critical Data Needs
Select Technologies to Address Concerns &
Objectives
Individual Technology Guidance
Individual Technology Guidance
Step 1
• Screened based on
demonstrated ability to
achieve a remedial
objective
• Should eliminate many
technologies from future
consideration
• Utilize contaminant
concern & remedial
objective screening
table
Screen Based on
Contaminant
Concerns and
Remedial
Objective(s)
CORRECTIVE ACTION CONTAMINANT CONCERNS, REMEDIAL OBJECTIVES, AND REMEDIAL TECHNOLOGIES TO CONSIDER
Contaminant Phase Contaminant Concern Remedial Objective Technologies to Consider
Sorbed
Surficial soils impacted above Tier I RBSLs and surface is not covered by an
impervious material
Remove or reduce surficial soil impacts to below Tier I RBSLs ● Excavation
Vadose zone soil impacted above Tier I RBSLs and/or Tier II SSTLs and
groundwater is impacted or potentially impactedRemove or reduce vadose zone soil impacts to below Tier I RBSLs and/or Tier II SSTLs
● Excavation
● AS/SVE
● SVE
● MPE (system or mobile, single or dual pump)
● Thermal Desorption
● Bioventing
● NSZD
Vadose zone soil impacted below Tier I RBSLs but groundwater impacted above
Tier I RBSLsRemove or reduce vadose zone mass to address contribution to groundwater
● Excavation
● AS/SVE
● SVE
● MPE (system or mobile, single or dual pump)
● Thermal Desorption
● Bioventing
● NSZD
Smear zone or saturated soil impacted and contributing to groundwater
contaminant migrationReduce mass in smear zone and/or saturated soil to address contribution to groundwater
● Excavation
● AS/SVE
● AS or O2 or O3 or Biosparge
● MPE (system or mobile, single or dual pump)
● Thermal Desorption
● SESR
● Activated Carbon
● NSZD
LNAPL
LNAPL is migrating Terminate LNAPL mass migration by mass recovery or mass control● Excavation
● MPE (system or mobile, single or dual pump)
LNAPL saturation is above residual saturation (mobile) and transmissivity is
above the recoverable rangeRecover LNAPL to the MEP (transmissivity range)
● Excavation
● MPE (system or mobile, single or dual pump)
● Thermal Desorption
● SESR
● EFR
LNAPL saturation is within the residual saturation range and a persistent source
of dissolved phase or vapor phase concernsIdentify appropriate phase change technology or excavate
● Excavation
● AS/SVE
● Thermal Desorption
● ISCO
● SESR
● NSZD
Dissolved
Impacted groundwater above Tier I RBSLs offsite and/or SSTLs onsite
Reduce groundwater concentrations to below Tier I RBSLs offsite and at POCs and to below Tier II
SSTLs onsite
● AS/SVE
● AS, O2, O3
● MPE (system or mobile, single or dual pump)
● ISCO
● Activated Carbon
● Biosparge
● MNA
Remove or address sorbed, LNAPL, or smear zone source material contributing to groundwater impact
● AS/SVE
● AS, O2, O3, or Biosparge
● MPE (system or mobile, single or dual pump)
● Thermal Desorption
● ISCO
● Activated Carbon
Domestic, irrigation, or water supply well impacted or potentially impacted above
Tier I RBSLs
Identify alternate water supply source
Modify the well intake
Reduce incoming groundwater concentrations to below Tier I RBSLs
● AS/SVE
● AS, O2, O3, or Biosparge
● MPE (system or mobile, single or dual pump)
● ISCO
● Activated Carbon
Engineered control to eliminate exposure to the receptor
Surficial water, springs, or sensitive environment POEs impactedReduce incoming groundwater concentrations to below Tier I RBSLs
● AS/SVE
● AS, O2, O3, or Biosparge
● MPE (system or mobile, single or dual pump)
● ISCO
● Activated Carbon
Implement measures to protect POEs from further impact
Impacted groundwater has intercepted a utility corridorEvaluate and mitigate migration potential and exposure to receptors
Evaluate and mitigate utility worker safety concerns
Vapor Petroleum vapor intrusion is impacting a utility corridor and/or structureRemediate source (LNAPL, sorbed, dissolved) to eliminate impacts See sorbed, LNAPL, and dissolved phase sections above
Engineered controls to prevent PVI Foundation vapor barrier, sub-slab depressurization system
Step 2
• Screen based on geologic
factors associated with
identified contaminant concerns
• Should eliminate technologies
that rely on certain geologic
conditions not present within
targeted treatment areas
• Consider contaminant mass
storage/transport zones
• Utilize technology overview and
applicable lithology screening
table
Screen Based
on Site
Geologic
Factors
Overview of Remedial Technologies
Technology Technology DescriptionApplicable
Lithology
Excavation Contaminant mass is physically removed and properly treated or disposed. F + C
Air Sparge/Soil Vapor Extraction
(AS/SVE)
AS injects air into the saturated zone to volatilize contaminants and SVE induces a
vacuum to remove vapors from the vadose zone. AS or SVE can be used individually if
site conditions are appropriate.
C
Biosparging and BioventingAir or oxygen is injected at low flow rates into the unsaturated zone (bioventing) or
saturated zone (biosparging) to stimulate contaminant biodegradation.F + C
Multi-Phase Extraction
An induced vacuum removes LNAPL, groundwater and vapor from the subsurface. A
single pump or dual pump system may be employed and a fixed or mobile system may be
designed depending on the complexity and magnitude of the environmental impact.
F + C
In-Situ Chemical Oxidation (ISCO)A chemical oxidant (e.g., H2O2, NaSO4, O3 ), typically with amendments, is introduced into
the subsurface to convert contaminants into innocuous byproducts.C
Activated Carbon
Activated carbon, typically with bio-nutrients and/or oxidants, is introduced in the
subsurface to adsorb contaminant mass (trap) and enable biological degradation
processes to occur (treat).
C
Surfactant-enhanced Subsurface
Remediation (SESR)
A surfactant is injected to increase LNAPL solubilization and mobility to enable recovery
of dissolved phase and LNAPL via extraction wells.C
Enhanced BiodegradationElectron acceptors (i.e., oxygen, nitrate, sulfate) or nutrients (i.e., trace elements) are
added to improve biodegradation rates within the saturated zone.F + C
Thermal Desorption
Energy is used to heat soil, pore space, and groundwater to volatilize contaminant mass
and reduce the viscosity and interfacial tension of LNAPL to enable recovery of liquid and
vapor contaminants via extraction wells.
F + C
Enhanced Fluid Recovery (EFR) LNAPL is hydraulically recovered by a vacuum-enhanced process. C
Monitored Natural Attenuation
(MNA) and Natural Source Zone
Depletion (NSZD)
Contaminant mass is naturally degraded or depleted over time by physical, chemical, or
biological processes.F + C
Step 3
Additional
Evaluation
Factors &
Comparative
Analysis
CSM
COST
Site Restrictions
Timeframe
Safety
Carbon Footprint
Waste Stream
Regulations/ Permits
Step 4
• To this point – a desktop
evaluation of existing
data and experience has
been conducted
• Step 4 includes the
collection of the
necessary field data and
performing pilot testing
• Critical data collection
aids in overall remedial
selection, design
efficiency, and
performance monitoring
Identify
Critical Data
Needs
Critical Data Aids In…..
• Remedial selection - Will the selected
technology effectively perform in the targeted
treatment area?
• Design efficiency - What information should be
gathered to maximize the effectiveness of the
technology?
• Performance monitoring – What baseline data
are needed prior to implementation?
Critical Data Examples
• Excavation – Grid pattern of soil borings
• AS/SVE – Air flow rates, vapor removal, radius of
influence
• Multi-Phase Extraction (MPE) – Liquid recovery
rates, drawdown
• ISCO – Soil oxidant demands, contaminant
distribution, mass flux
• MNA – Degradation rates, geochemical setting
Step 5
• A culmination of Steps 1-4
• Multiple contaminant
concerns may warrant
repeating the technology
selection process
• Identification of
performance metrics and
remedial endpoints
• Treatment train or
combined remedy
approach may be
necessary
Select
Technologies
to Address
Concerns &
Objectives
Treatment Train/
Combined Remedy
Treatment Train
• A sequence of multiple remedial technologies to achieve site closure
• Formerly, a single remedial technology to closure was the norm
• More practical to sequence remedial technologies based on contaminant concerns and remedial objectives
• Consider starting with a primary technology (i.e., excavation) tailored for higher contaminant mass
• Continue with a 2nd treatment technology (ISCO) and possibly a tertiary polishing step (i.e., CBI) to address remaining contaminant mass and to achieve objectives and elimination of contaminant concern
Combined Remedy
• Similar approach would be under a
combined remedy (i.e., AS/SVE) in that
methods are employed concurrently, even
in different plume areas
• Treatment train or combined remedy?
Both rely on performance metrics to
measure remedial progress
Quick Recap
Utilize the 5 - Step Screening Process to evaluate, screen out and select a remedial technology
• Step 1 - Screen based on identified concerns and objectives –use table
• Step 2 – Screen based on site geologic factors – use table
• Step 3 – Screen based on additional evaluation factors – cost, GSR, etc.
• Step 4 – Collection of critical data – selection, efficiency, performance
• Step 5 – Select the remedial technology
• Consider a sequence (treatment train) or combination (combined remedy) of remedial technologies to achieve objectives and to abate contaminant concerns
CAP Preparation Exercise
Part 2
Technology Selection
CAP Preparation Exercise Part 2
Based on the results of Exercise 1, use
the 5-step screening process to:
• Select remedial technologies
• Plan implementation
“Concerns” table---
CORRECTIVE ACTION CONTAMINANT CONCERNS AND REMEDIAL OBJECTIVES IDENTIFICATION TABLE
TPH Benzene
Surficial soils impacted above Tier I
RBSLs and surface is not covered by
an impervious material no
Remove or reduce surficial soil impacts to below Tier I
RBSLs no
Vadose zone soil impacted above Tier
I RBSLs and/or Tier II SSTLs and
groundwater is impacted or potentially
impacted no
Remove or reduce vadose zone soil impacts to below Tier I
RBSLs and/or Tier II SSTLs no
Vadose zone soil impacted below Tier
I RBSLs but groundwater impacted
above Tier I RBSLs yes
Remove or reduce vadose zone mass to address
contribution to groundwater yes
Smear zone or saturated soil
impacted and contributing to
groundwater contaminant migration unknown
Reduce mass in smear zone and/or saturated soil to
address contribution to groundwater yes
LNAPL is migrating no
Terminate LNAPL mass migration by mass recovery or
mass control no
LNAPL saturation is above residual
saturation (mobile) and transmissivity
is above the recoverable range yes Recover LNAPL to the MEP (transmissivity range) yes
LNAPL saturation is within the
residual saturation range and a
persistent source of dissolved phase
or vapor phase concerns yes Identify appropriate phase change technology or excavate yes 2852
Reduce groundwater concentrations to below Tier I RBSLs
offsite and at POCs and to below Tier II SSTLs onsite yes 250 3
Remove or address source material contributing to
groundwater impact yes
Identify alternate water supply source no
Modify the well intake no
Reduce incoming groundwater concentrations to below Tier I
RBSLs no
Engineered control to eliminate exposure to the receptor no
Reduce concentrations to below Tier I RBSLs at property
boundary and offsite or Tier II SSTLs onsite no
Implement measures to protect POEs from further impact no
Evaluate and mitigate migration potential and exposure to
receptors no
Evaluate and mitigate utility worker safety concerns no
Contaminant
Phase Contaminant Concern
Is this
concern
present? Remedial Objective
Treatment
Area
Identified?
Contaminant Mass
Estimate (kg)
no
Sorbed
LNAPL
Dissolved
Impacted groundwater above Tier I
RBSLs offsite and/or SSTLs onsite yes
Domestic, irrigation, or water supply
well impacted or potentially impacted
above Tier I RBSLs no
Surficial water, springs, or sensitive
environment POEs impacted no
Impacted groundwater has intercepted
a utility corridor
See OPS Guidance
Screening Process
Screen Based on Contaminant Concerns & Remedial Objective(s)
Screen Based on Site Geologic Factors
Prioritize Additional Evaluation Factors and Perform Comparative
Analysis
Identify Critical Data Needs
Select Technologies to Address Concerns &
Objectives
Do for each
concern
Step 1 – Screen Technologiesfor LNAPL concerns (from CAP guidance)
LNAPL
LNAPL is migratingTerminate LNAPL mass migration
by mass recovery or mass control
● Excavation
● MPE (system or mobile, single
or dual pump)
LNAPL saturation is above
residual saturation (mobile) and
transmissivity is above the
recoverable range
Recover LNAPL to the MEP
(transmissivity range)
● Excavation
● MPE (system or mobile,
single or dual pump)
● Thermal Desorption
● SESR
● EFR
LNAPL saturation is within the
residual saturation range and a
persistent source of dissolved
phase or vapor phase concerns
Identify appropriate phase change
technology or excavate
● Excavation
● AS/SVE
● Thermal Desorption
● ISCO
● SESR
● NSZD
Technologies to Consider
for Mobile LNAPL (from Step 1 table)
1. Excavation
2. MPE (multi-phase extraction)
3. Thermal Desorption
4. SESR (surfactant enhanced subsurface remediation)
5. EFR (enhanced fluid recovery)
6. Skimming added
Step 2 - Geology
Technologies to Consider
for Mobile LNAPL (from Step 2 table)
1. Excavation
2. MPE (multi-phase extraction)
3. Thermal Desorption
4. SESR (surfactant enhanced subsurface remediation)
5. EFR (enhanced fluid recovery)
6. Skimming
Step 3 – Other factors (mobile LNAPL)
Design a matrixFeasibility factors might include: access, waste handling,
regulations & permits, safety, carbon footprint
EXCAVATION MPETHERMAL
DESORPTIONSESR EFR SKIMMING
COST
TIMEFRAME
TECHNICAL
FEASIBILITY
BOULDERS
AND DEPTH
EXCESS
WATER
HIGH HEAT
FLUX
HARD TO
DISTRIBUTE /
RECOVER
Step 3 – Other factors (mobile LNAPL)
EXCAVATION MPETHERMAL
DESORPTIONSESR EFR SKIMMING
COSTLOW TO
MODERATE
MODERATE TO
HIGH
TIMEFRAME
SHORT
(EMERGENCY
USE)
SHORT
TECHNICAL
FEASIBILITY
BOULDERS
AND DEPTH
EXCESS
WATER
HIGH HEAT
FLUX
HARD TO
DISTRIBUTE/
RECOVER
GOOD IF LIMIT
GW RECOVERY
INADEQUATE
LNAPL
PRESENT
Step 4
• EFR was selected.
• We identify Critical Data Needs to:
• Collect baseline data
What field parameters may change?
• Verify the technology (Will it work?)
What equipment data do I collect?
• Design the system and/or program
Step 4 - Identify Critical Data Needs
Step 4
• Critical Data Needs (EFR)
• Measure depth to LNAPL and water
• Record over several hours:
Vacuum at extraction point(s) and wells (ROI)
Airflow data
Emissions/LNAPL recovery (in the truck)
Changes outside the area of influence
• Record LNAPL recovery in the well
to judge EFR frequency and endpoint
(quasi-Tn tests)
Step 5
Select the technology to address the
contaminant concern and achieve the
remedial objective
In some cases, testing more than one technology
may be necessary to choose the best
In this case, selection occurred at Step 3
Complete Steps
1-5 for dissolved
phase concern.
Residual LNAPL & adsorbed
phases must also be addressed,
but not in this exercise
Update the table--CORRECTIVE ACTION CONTAMINANT CONCERNS AND REMEDIAL OBJECTIVES IDENTIFICATION TABLE
TPH Benzene
Surficial soils impacted above Tier I
RBSLs and surface is not covered by
an impervious material no
Remove or reduce surficial soil impacts to below Tier I
RBSLs no
Vadose zone soil impacted above Tier
I RBSLs and/or Tier II SSTLs and
groundwater is impacted or potentially
impacted no
Remove or reduce vadose zone soil impacts to below Tier I
RBSLs and/or Tier II SSTLs no
Vadose zone soil impacted below Tier
I RBSLs but groundwater impacted
above Tier I RBSLs yes
Remove or reduce vadose zone mass to address
contribution to groundwater yes Soil Vapor Extraction
Smear zone or saturated soil
impacted and contributing to
groundwater contaminant migration unknown
Reduce mass in smear zone and/or saturated soil to
address contribution to groundwater yes Soil Vapor Extraction
LNAPL is migrating no
Terminate LNAPL mass migration by mass recovery or
mass control no
LNAPL saturation is above residual
saturation (mobile) and transmissivity
is above the recoverable range yes Recover LNAPL to the MEP (transmissivity range) yes Enhanced Fluid Recovery
LNAPL saturation is within the
residual saturation range and a
persistent source of dissolved phase
or vapor phase concerns yes Identify appropriate phase change technology or excavate yes 2852 AS/SVE
Reduce groundwater concentrations to below Tier I RBSLs
offsite and at POCs and to below Tier II SSTLs onsite yes 250 3 Air Sparging
Remove or address source material contributing to
groundwater impact yes Air Sparging
Identify alternate water supply source no
Modify the well intake no
Reduce incoming groundwater concentrations to below Tier I
RBSLs no
Engineered control to eliminate exposure to the receptor no
Reduce concentrations to below Tier I RBSLs at property
boundary and offsite or Tier II SSTLs onsite no
Implement measures to protect POEs from further impact no
Evaluate and mitigate migration potential and exposure to
receptors no
Evaluate and mitigate utility worker safety concerns noImpacted groundwater has intercepted
a utility corridor
Contaminant Mass
Estimate (kg)
Proposed Remedial Option
no
Sorbed
LNAPL
Dissolved
Impacted groundwater above Tier I
RBSLs offsite and/or SSTLs onsite yes
Domestic, irrigation, or water supply
well impacted or potentially impacted
above Tier I RBSLs no
Surficial water, springs, or sensitive
environment POEs impacted no
Contaminant
Phase Contaminant Concern
Is this
concern
present? Remedial Objective
Treatment
Area
Identified?
Update the table--
Implementation
• There are usually multiple contaminant concerns
for a release
• Certain technologies may be able to address
multiple remedial objectives and may offer the
greatest utility
• Utilize the process to address multiple concerns
• treatment train = series, in one area
• combined remedy = parallel, different areas
Treatment Areas
TPH Benzene
Surficial soils impacted above Tier I
RBSLs and surface is not covered by
an impervious material no
Remove or reduce surficial soil impacts to below Tier I
RBSLs no
Vadose zone soil impacted above Tier
I RBSLs and/or Tier II SSTLs and
groundwater is impacted or potentially
impacted no
Remove or reduce vadose zone soil impacts to below Tier I
RBSLs and/or Tier II SSTLs no
Vadose zone soil impacted below Tier
I RBSLs but groundwater impacted
above Tier I RBSLs yes
Remove or reduce vadose zone mass to address
contribution to groundwater yes Soil Vapor Extraction 1
Smear zone or saturated soil
impacted and contributing to
groundwater contaminant migration unknown
Reduce mass in smear zone and/or saturated soil to
address contribution to groundwater yes Soil Vapor Extraction 1
LNAPL is migrating no
Terminate LNAPL mass migration by mass recovery or
mass control no
LNAPL saturation is above residual
saturation (mobile) and transmissivity
is above the recoverable range yes Recover LNAPL to the MEP (transmissivity range) yes Enhanced Fluid Recovery 1
LNAPL saturation is within the
residual saturation range and a
persistent source of dissolved phase
or vapor phase concerns yes Identify appropriate phase change technology or excavate yes 2852 AS/SVE (then NSZD?) 2
Reduce groundwater concentrations to below Tier I RBSLs
offsite and at POCs and to below Tier II SSTLs onsite yes 250 3 Air Sparging 1
Remove or address source material contributing to
groundwater impact yes Air Sparging 1
Identify alternate water supply source no
Modify the well intake no
Reduce incoming groundwater concentrations to below Tier I
RBSLs no
Engineered control to eliminate exposure to the receptor no
Reduce concentrations to below Tier I RBSLs at property
boundary and offsite or Tier II SSTLs onsite no
Implement measures to protect POEs from further impact no
Evaluate and mitigate migration potential and exposure to
receptors no
Evaluate and mitigate utility worker safety concerns no
CORRECTIVE ACTION CONTAMINANT CONCERNS AND REMEDIAL OBJECTIVES IDENTIFICATION TABLE
Contaminant
Phase Contaminant Concern
Is this
concern
present? Remedial Objective
Treatment
Area
Identified?
Contaminant Mass
Estimate (kg)
Proposed Remedial Option
Treatment
Train Phase
no
Sorbed
LNAPL
Dissolved
Impacted groundwater above Tier I
RBSLs offsite and/or SSTLs onsite yes
Domestic, irrigation, or water supply
well impacted or potentially impacted
above Tier I RBSLs no
Surficial water, springs, or sensitive
environment POEs impacted no
Impacted groundwater has intercepted
a utility corridor
Update the table--
TPH Benzene
Surficial soils impacted above Tier I
RBSLs and surface is not covered by
an impervious material no
Remove or reduce surficial soil impacts to below Tier I
RBSLs no
Vadose zone soil impacted above Tier
I RBSLs and/or Tier II SSTLs and
groundwater is impacted or potentially
impacted no
Remove or reduce vadose zone soil impacts to below Tier I
RBSLs and/or Tier II SSTLs no
Vadose zone soil impacted below Tier
I RBSLs but groundwater impacted
above Tier I RBSLs yes
Remove or reduce vadose zone mass to address
contribution to groundwater yes Soil Vapor Extraction 1
Smear zone or saturated soil
impacted and contributing to
groundwater contaminant migration unknown
Reduce mass in smear zone and/or saturated soil to
address contribution to groundwater yes Soil Vapor Extraction 1
LNAPL is migrating no
Terminate LNAPL mass migration by mass recovery or
mass control no
LNAPL saturation is above residual
saturation (mobile) and transmissivity
is above the recoverable range yes Recover LNAPL to the MEP (transmissivity range) yes Enhanced Fluid Recovery 1
LNAPL saturation is within the
residual saturation range and a
persistent source of dissolved phase
or vapor phase concerns yes Identify appropriate phase change technology or excavate yes 2852 AS/SVE (then NSZD?) 2
Reduce groundwater concentrations to below Tier I RBSLs
offsite and at POCs and to below Tier II SSTLs onsite yes 250 3 Air Sparging 1
Remove or address source material contributing to
groundwater impact yes Air Sparging 1
Identify alternate water supply source no
Modify the well intake no
Reduce incoming groundwater concentrations to below Tier I
RBSLs no
Engineered control to eliminate exposure to the receptor no
Reduce concentrations to below Tier I RBSLs at property
boundary and offsite or Tier II SSTLs onsite no
Implement measures to protect POEs from further impact no
Evaluate and mitigate migration potential and exposure to
receptors no
Evaluate and mitigate utility worker safety concerns no
CORRECTIVE ACTION CONTAMINANT CONCERNS AND REMEDIAL OBJECTIVES IDENTIFICATION TABLE
Contaminant
Phase Contaminant Concern
Is this
concern
present? Remedial Objective
Treatment
Area
Identified?
Contaminant Mass
Estimate (kg)
Proposed Remedial Option
Treatment
Train Phase
no
Sorbed
LNAPL
Dissolved
Impacted groundwater above Tier I
RBSLs offsite and/or SSTLs onsite yes
Domestic, irrigation, or water supply
well impacted or potentially impacted
above Tier I RBSLs no
Surficial water, springs, or sensitive
environment POEs impacted no
Impacted groundwater has intercepted
a utility corridor
Concerns and objectives addressed under the first treatment train
phase should be identified with a “1”. Objectives to be addressed later
should be identified as the next phase of remediation (e.g., 2 or 3).
Update the table--
Performance Metrics
Endpoint Identification
Remedial Milestones
Performance Metrics
Measurable characteristics
that track the remedial
progress of a selected
technology achieving a
remedial objective and
abating a contaminant
concern
Performance Metrics Examples
• AS/SVE - Air emission samples to evaluate
contaminant mass
• ISCO - Data to evaluate distribution of an in-
situ application
• SVE - Interim or final soil confirmation samples
• MNA – Dissolved phase monitoring
(Tier I/Tier II Endpoint)
Endpoint Identification
• Predetermined value (i.e., Tier 1, Tier 2
RBSLs) that describes when a technology
has achieved the limits of beneficial
application
• Should account for expectations of the
selected remedial technology
• Does not necessarily eliminate contaminant
concern(s) described in the CSM
Remedial Milestones
Anticipated points throughout
remediation implementation to
evaluate progress towards
remedial endpoint.
Remedial Milestone Examples
• Air emission samples to evaluate remedial
progress
• Mass reduction comparison based on initial
contaminant mass (exponential decline,
not linear)
• Dissolved phase concentrations
remediated to 25%, 50%, 75% of SSTL, or
RBSL
Monitoring Network &
Sampling Frequency
Monitoring Well Network
• Should be designed to be representative of
the contaminant plume and coincide with the
targeted treatment areas
• Allows for continued collection of critical data
• Specific monitoring wells should have
endpoints (i.e., Tier I, Tier II) or other
purposes (i.e., plume migration) clearly
identified
Monitoring Well Frequency
• Frequency should:
• coincide with remedial milestones to evaluate progress towards remedial endpoint (i.e., RBSL, SSTL)
• be based on an expectation that data collection continues to progress a release towards achieving remedial objectives
• May vary based on:
• Intended
purpose (i.e.,
POC vs source
area)
• Historical data
• Anticipated
remedial change
O&M and Monitoring
Mimic this matrix to organize O&M, sample parameters, etc.
LOCATION 1Q18 2Q18 3Q18 4Q18 1Q19 2Q19 3Q19 4Q19 1Q20 2Q20 3Q20 4Q20 SUM
MW-1 1 1 1 1 1 1 6
MW-2 1 1
MW-3 1 1 1 1 1 1 6
MW-4 1 1 1 1 1 1 6
MW-5 1 1
MW-6 1 1 1 1 1 1 6
MW-7 1 1 2
MW-8 1 1 1 1 1 1 6
MW-9 1 1 2
MW-10 1 1 2
VP-1 1 1 1 3
VP-2 1 1 1 3
soil MW-3(14') 1 1 1 3
SUMS 2 7 2 9 0 5 0 11 0 5 0 6 38 Total GW
6 Total VP
3 Total soil
PROPOSED MONITORING PLANC
AP
IM
PLE
ME
NT
AT
ION
Quick Recap
• Identification of performance
metrics allow for evaluation
of remedial technology
progress to eliminating
identified contaminant
concerns
• Remedial endpoint
identification allows for a
estimate of time to achieve
remedial objectives
• Remedial milestones are
predetermined points used to
evaluate progress towards a
remedial endpoint
• Performance monitoring
involves establishing a
sampling network that is
representative contaminant
plume and within targeted
treatment areas
• Frequency for performance
monitoring should coincide
with remedial milestones to
evaluate progress towards
remedial endpoint
CAP Preparation Exercise
Part 3
Implementation
Develop a SMART Objective
• Identification of performance metrics and
remedial endpoints
• Estimation of time to reach the endpoints
• Identification of milestones to evaluate
the progress toward the endpoints
Corrective Action Plan Preparation Training – Exercise 3: Establish Performance Metrics, Remedial Milestones and
Endpoints to Achieve Remedial Objectives
Identify the following for the technology of AS/SVE to address the concerns of: 1. Impacted groundwater above Tier I
RBSLs offsite and/or SSTLs onsite, 2. Vadose zone soil impacted below Tier I RBSLs but groundwater impacted above Tier
I RBSLs, 3. LNAPL saturation is within the residual saturation range and persistent source of dissolved phase or vapor
phase concerns.
1. The performance metrics that will be used to measure the progress of the technology
2. The remedial endpoint that signifies the technology has achieved its objective
3. The estimated timeframe to achieve the objective
4. Anticipated milestones
5. A proposed reporting schedule based on the milestones
6. Describe how this plan is a SMART Objective Specific - Measurable - Agreed Upon - Realistic - Time-based -
Summary
• CAP preparation starts
with contaminant
concern ID
• Contaminant concerns
drive remedial goals
and objectives
• Remedial
goals/objectives should
be SMART for identified
areas
• SMART objectives include performance metrics, endpoints and milestones
• Targeted treatment areas should be specific to where contaminant concerns exist and where remedial objectives have been identified
• Evaluate, screen out, select the remedial technology based on the 5-step screening process – BASIS of SELECTION
Summary
• Technology selection does not represent the END! If multiple concerns, consider a treatment train or combined remedy
• Identify sampling needs, network, and frequency to coincide with milestones and to evaluate progress towards established endpoints
• As a REP, the expectations are that a submitted CAP will accurately detail each of the components that have been discussed here today
• If a submitted CAP does not meet the expectations as provided in OPS Guidance or through continuing education, the plan could be subject to denial