Remedial Action

A Remedial Action Plan (RAP) is the roadmap for actively removing contamination from a site. The goal is to address the strategy that will be implemented and describe why it best is the best fit for the site. There are a wide range of strategies for remediation, e.g., free product removal, land farming of soil, blending of impacted soil, excavating and hauling of impacted soil, bioremediation of soil, soil vapor extraction, pumping and treating of groundwater, and air sparging, just to name a few.

From the client perspective some key factors for consideration during the remedial action phase may include time horizon, budget, the end use of the property, and the long-term cost of closure.

From the consultant’s perspective key considerations will include an evaluation of the media requiring remediation (soil, groundwater, or soil gas). The stage of the project, for example, a soil vapor remedial strategy will be different for an undeveloped site with no building from a site that has an existing structure that is at risk for vapor intrusion. The consultant will also need to inform the client of the long-term costs of a passive strategy like an engineering cap that will require routine engineering inspections to comply with regulations or that of an active strategy such as a sub slab depressurization system run on electricity. Additionally, while it may be valuable in the short term to fast-track regulatory closure through a deed restriction, that could result in limiting the end use of the site. For example, many deed restrictions forbit sensitive land use e.g., a day care center. A site’s geology is incredibly important because a pump and treat remedial action strategy may not be particularly effective in soils with low permeability. The risk of nearby receptors such as water withdrawal wells or discharges of wind-blown fugitive dust also need to be considered.

For that reason, there is no one-size-fits-all remedial action strategy and it is important to be creative and collaborative to meet the goal of achieving regulatory closure.