Effective Corrective Action Plan Preparation Course Presentation.pdfCAP guidance preparation...

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


(Part 2)

• Performance

Metrics/Endpoints/Remedial

Milestones

• Groundwater Monitoring Network

and Sampling Frequency


(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

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



● 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



● SESR

● Activated Carbon

● NSZD

LNAPL

LNAPL is migrating Terminate LNAPL mass migration by mass recovery or mass control● Excavation


LNAPL saturation is above residual saturation (mobile) and transmissivity is

above the recoverable rangeRecover LNAPL to the MEP (transmissivity range)

● Excavation



● 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


● 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


● ISCO


● Biosparge

● MNA

Remove or address sorbed, LNAPL, or smear zone source material contributing to groundwater impact

● AS/SVE

● AS, O2, O3, or Biosparge



● ISCO


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



● ISCO


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



● ISCO


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


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---


TPH Benzene



an impervious material no


RBSLs no




impacted no


RBSLs and/or Tier II SSTLs no



above Tier I RBSLs yes


contribution to groundwater yes



groundwater contaminant migration unknown


address contribution to groundwater yes



mass control no



is above the recoverable range yes Recover LNAPL to the MEP (transmissivity range) yes




or vapor phase concerns yes Identify appropriate phase change technology or excavate yes 2852


offsite and at POCs and to below Tier II SSTLs onsite yes 250 3


groundwater impact yes

Identify alternate water supply source no

Modify the well intake no


RBSLs no

Engineered control to eliminate exposure to the receptor no


boundary and offsite or Tier II SSTLs onsite no

Implement measures to protect POEs from further impact no


receptors no

Evaluate and mitigate utility worker safety concerns no

Contaminant


Is this

concern


Treatment

Area

Identified?

Contaminant Mass

Estimate (kg)

no

Sorbed

LNAPL

Dissolved


RBSLs offsite and/or SSTLs onsite yes





environment POEs impacted no


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)


● SESR

● EFR



persistent source of dissolved

phase or vapor phase concerns

Identify appropriate phase change

technology or excavate

● Excavation

● AS/SVE


● 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





RBSLs no




impacted no







contribution to groundwater yes Soil Vapor Extraction





address contribution to groundwater yes Soil Vapor Extraction



mass control no



is above the recoverable range yes Recover LNAPL to the MEP (transmissivity range) yes Enhanced Fluid Recovery




or vapor phase concerns yes Identify appropriate phase change technology or excavate yes 2852 AS/SVE


offsite and at POCs and to below Tier II SSTLs onsite yes 250 3 Air Sparging


groundwater impact yes Air Sparging




RBSLs no






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








Contaminant


Is this

concern


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





RBSLs no




impacted no







contribution to groundwater yes Soil Vapor Extraction 1





address contribution to groundwater yes Soil Vapor Extraction 1



mass control no



is above the recoverable range yes Recover LNAPL to the MEP (transmissivity range) yes Enhanced Fluid Recovery 1




or vapor phase concerns yes Identify appropriate phase change technology or excavate yes 2852 AS/SVE (then NSZD?) 2


offsite and at POCs and to below Tier II SSTLs onsite yes 250 3 Air Sparging 1


groundwater impact yes Air Sparging 1




RBSLs no






receptors no



Contaminant


Is this

concern


Treatment

Area

Identified?

Contaminant Mass

Estimate (kg)


Treatment

Train Phase

no

Sorbed

LNAPL

Dissolved









a utility corridor

Update the table--

TPH Benzene





RBSLs no




impacted no







contribution to groundwater yes Soil Vapor Extraction 1





address contribution to groundwater yes Soil Vapor Extraction 1



mass control no



is above the recoverable range yes Recover LNAPL to the MEP (transmissivity range) yes Enhanced Fluid Recovery 1




or vapor phase concerns yes Identify appropriate phase change technology or excavate yes 2852 AS/SVE (then NSZD?) 2


offsite and at POCs and to below Tier II SSTLs onsite yes 250 3 Air Sparging 1


groundwater impact yes Air Sparging 1




RBSLs no






receptors no



Contaminant


Is this

concern


Treatment

Area

Identified?

Contaminant Mass

Estimate (kg)


Treatment

Train Phase

no

Sorbed

LNAPL

Dissolved









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


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

Effective Corrective Action Plan Preparation Course Presentation.pdfCAP guidance preparation...

Documents

Transcript of Effective Corrective Action Plan Preparation Course Presentation.pdfCAP guidance preparation...