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Corrective Action Plans – Part A and Part B

Corrective Action Plans (CAP) are required to be conducted at a property that has a known environmental impact. An initial CAP (Part A) is designed to identify the source area(s) of the known environmental impact to the soil and groundwater. Soil and groundwater assessment will include the installation of soil borings and groundwater monitoring wells. Soil borings are installed utilizing a variety of drilling technologies, selected based on site specific requirements. Soil samples are collected during the drilling activities at specified locations and depth intervals. Soil samples can be screened in the field using hand held analyzers to identify the optimal soil samples to be selected for laboratory analysis. The laboratory analyses are selected based on the known substances released, and to satisfy regulatory requirements. Field parameters and observations are recorded during the drilling activities and detailed soil boring logs are prepared for inclusion within report documentation.

Corrective Action Plan - Part A & Part B

When environmental contaminants may have reached the groundwater, groundwater monitoring wells are installed within soil borings. Properly constructed groundwater monitoring wells are designed and installed to meet site conditions and the contaminants of concern. Groundwater samples are subsequently collected for laboratory analysis. The locations of groundwater monitoring wells are added to the site plan and vertically surveyed so that the depth to groundwater can be used to calculate the direction of groundwater.

 

All environmental assessment activities are conducted with risk in mind. Environmental contamination must be considered in the context of the threat to nearby potential receptors. Regulatory standards are utilized to determine action levels, and contaminant concentrations are compared with action levels to evaluate the potential for risk to nearby potential receptors including surface water bodies (creeks, streams, lakes) and drinking water supply wells.

 

In Georgia when assessing former underground storage tank sites and other petroleum impacted properties, a Corrective Action Plan – Part A report summarizes the initial assessment activities completed. Georgia’s Underground Storage Tank Management Program (USTMP) outlines specific requirements for both the field activities and the reporting to satisfy the CAP – Part A requirements. An important part of a CAP – Part A report prepared for USTMP review is preparation of the essential paperwork to apply for reimbursement through the Georgia Underground Storage Tank Trust Fund. If the initial Corrective Action Plan – Part A results indicate that no additional investigation is necessary, a request can be made to the appropriate regulatory authority for a status of “No Further Action Required”. Upon approval, conditional site closure activities are initiated.

 

A Corrective Action Plan – Part A is designed to identify the source areas and ideally the areas of the highest contamination. Typically, additionally investigation will be required to properly define the horizontal and vertical extents of the soil and groundwater contamination. A Site Investigation Plan (SIP) is developed that includes the installation and sampling of a number of additional soil borings and groundwater monitoring wells. Several phases of site investigation may be required to properly delineate the extents of the contamination, and results are often summarized within interim Site Investigation Summary (SIS) reports. Once the SIS phases of assessment are completed, and if contaminant concentrations exceed the established regulatory thresholds and require a more extensive approach, a CAP – Part B will be required.

 

A Corrective Action Plan – Part B is intended to be the final stage of site assessment that will present a complete representation of the environmental impacts on a property. A thorough description of the environmental conditions are presented along with local and site hydrology, local groundwater conditions, direction of groundwater flow, discussion of site lithology, stratigraphic boring logs, and stratigraphic cross-sections. Risk-Based Corrective Action (RBCA) methodologies are employed. When necessary, computer based groundwater fate and transport modeling can be used to ascertain whether an impacted groundwater contaminant plume may be a risk to nearby potential receptors. If there is no potential risk to nearby surface waters or drinking water sources, and the contaminant concentrations fall below the regulatory action standards, no site remediation may be required and a long-term groundwater monitoring program may be the only corrective action required. A Monitoring Only Plan is designed to establish a long term depiction of how site conditions may change over seasonal groundwater fluctuations, and to reinforce that site conditions are stable and no active remediation is required. At the end of the long-term monitoring program, if an established trend of contaminant concentrations is observed and no dramatic increases are observed in the contaminant concentrations, a status of No Further Action Required will be requested.

 

If the site conditions warrant active remediation, a thorough evaluation of the remedial alternatives is important to meet site objectives within established timeframes and monetary budgets. The objectives of corrective action may include remediation/treatment of contaminated backfill material and native soils, remediation of subsurface soils, remediation of groundwater contamination, and remediation and/or mitigation of surface water impacts. The most efficient and cost-effective remedial alternatives will be selected for a property. If a fixed based remediation system is required, we will select and design a remediation system specifically tailored to the site conditions. The Corrective Action Plan – Part B will also include a plan for startup operations, long-term operational and remedial progress monitoring, schedules for scheduled inspections and preventative maintenance, and a confirmatory sampling plan. A milestone schedule is established to track remedial progress with an eye on the remedial objectives to ensure that conditions for site closure are achieved.

 

Whatever the challenges presented when a Corrective Action Plan is required, Point to Point Environmental is committed to achieving your site objectives in a cost effective manner.