Preparation REP Continuing Education Course Remediation Petroleum - - PowerPoint PPT Presentation

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

• bjectives 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

• r vapor phase concerns

Identify appropriate phase change technology or excavate Reduce groundwater concentrations to below Tier I RBSLs

• ffsite 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

• bjective
• Should eliminate many

technologies from future consideration

• Utilize contaminant

concern & remedial

• bjective 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

• Excavation

• Excavation
• AS/SVE
• SVE
• MPE (system or mobile, single or dual pump)
• Thermal Desorption
• Bioventing
• NSZD

• Excavation
• AS/SVE
• SVE
• MPE (system or mobile, single or dual pump)
• Thermal Desorption
• Bioventing
• NSZD

• 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

• Excavation
• MPE (system or mobile, single or dual pump)

• Excavation
• MPE (system or mobile, single or dual pump)
• Thermal Desorption
• SESR
• EFR

• f dissolved phase or vapor phase concerns

• Excavation
• AS/SVE
• Thermal Desorption
• ISCO
• SESR
• NSZD

Dissolved

• AS/SVE
• AS, O2, O3
• MPE (system or mobile, single or dual pump)
• ISCO
• Activated Carbon
• Biosparge
• MNA

• AS/SVE
• AS, O2, O3, or Biosparge
• MPE (system or mobile, single or dual pump)
• Thermal Desorption
• ISCO
• Activated Carbon

• AS/SVE
• AS, O2, O3, or Biosparge
• MPE (system or mobile, single or dual pump)
• ISCO
• Activated Carbon

• AS/SVE
• AS, O2, O3, or Biosparge
• MPE (system or mobile, single or dual pump)
• ISCO
• Activated Carbon

Vapor

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

• n Site

Geologic Factors

Overview of Remedial Technologies

Technology Technology Description Applicable 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 Bioventing Air 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

• f dissolved phase and LNAPL via extraction wells.

C Enhanced Biodegradation Electron 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

• bjectives 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---

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

• r vapor phase concerns

yes Identify appropriate phase change technology or excavate yes 2852 Reduce groundwater concentrations to below Tier I RBSLs

• ffsite and at POCs and to below Tier II SSTLs onsite

yes 250 3 Remove or address source material contributing to groundwater impact yes I Sorbed LNAPL Impacted groundwater above Tier I RBSLs offsite and/or SSTLs onsite yes

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 Technologies

for LNAPL concerns (from CAP guidance)

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

• Excavation
• MPE (system or mobile, single
• r 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 matrix

Feasibility factors might include: access, waste handling, regulations & permits, safety, carbon footprint

EXCAVATION MPE THERMAL DESORPTION SESR 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 MPE THERMAL DESORPTION SESR EFR SKIMMING COST LOW 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

• r vapor phase concerns

yes Identify appropriate phase change technology or excavate yes 2852 AS/SVE Reduce groundwater concentrations to below Tier I RBSLs

• ffsite 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 no Impacted 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

• r 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

• ffsite 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--

RBSLs and/or Tier II SSTLs no r Remove or reduce vadose zone mass to address contribution to groundwater yes Soil Vapor Extraction 1 n Reduce mass in smear zone and/or saturated soil to address contribution to groundwater yes Soil Vapor Extraction 1 Terminate LNAPL mass migration by mass recovery or mass control no Recover LNAPL to the MEP (transmissivity range) yes Enhanced Fluid Recovery 1 Identify appropriate phase change technology or excavate yes 2852 AS/SVE (then NSZD?) 2 Reduce groundwater concentrations to below Tier I RBSLs

• ffsite 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 I

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 5 11 5 6 38 Total GW 6 Total VP 3 Total soil

PROPOSED MONITORING PLAN

CAP IMPLEMENTATION

Quick Recap

• Identification of performance

metrics allow for evaluation

• f 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

• f 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