Effective Corrective Action Plan Preparation REP Continuing Education Course
Remediation Petroleum Program Compliance Fund
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 CAP Preparation Exercise (Part 2) • Define Remedial Goals and • Objectives Performance Metrics/Endpoints/Remedial • Milestones Identify Targeted Treatment Areas • • Groundwater Monitoring Network CAP Preparation Exercise and Sampling Frequency (Part 1) • • CAP Preparation Exercise Evaluate/Screen Out/ Select (Part 3) Remedial Technology • • Summary/Questions Treatment Train/Combined Remedy
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. • Each phase may Comprised of four present multiple distinct contaminant contaminant phases to evaluate: concerns 1. Sorbed (surficial, • Clearly identified subsurface soil) contaminant 2. Dissolved concerns lead to a (groundwater refined CSM with ingestion) well-defined 3. Vapor (soil vapor and remedial objectives groundwater to IA) and goals 4. LNAPL
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 • S pecific - Targeted treatment area and technology-specific endpoints are clearly stated • M easurable – Performance metrics that demonstrate progress towards the endpoints • A greed Upon – Concerns, goals, objectives treatment areas metrics, endpoints • R ealistic – Demonstrated ability to achieve objective • T ime-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 Use the data tables includes the following: and figures to • complete the CAP Cover page bullet list summary of site assessment preparation table to results identify contaminant • Site assessment data tables concerns/remedial for soil, LNAPL, groundwater, objectives and and surface water sketch the targeted • GW elevation map, geologic treatment areas on cross sections, and a plume the cross sections map showing LNAPL and and plume map dissolved benzene distribution • CAP preparation table
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