How should I review a Remedial Action Plan?

What is a Remedial Action Plan?

There are four steps to reviewing a Remedial Action Plan. To review a RAP you should:

1. Evaluate the sampling and testing methods

•   What contaminants were sampled? (How to Check)
•   Is this consistent with what was used at the site and what has been found previously (if prior sampling and analysis have been conducted)? (Process Information)
•   Are there any other contaminants that should have been sampled? (Suggestion List)
•   Were soil, air, and groundwater tested? (How to Check)
•   Was the site adequately investigated? (Site Assessment and Sampling)
•   Were enough samples taken across the site to provide a good description of the contamination? (Site Assessment and Sampling)
•   Were the analyses done properly (e.g., adequate detection limits and lab work)? (MDEQ Recommended Methods and Limits) (Methods Information)




2. Become knowledgeable with the contaminants present on the site

•   Where are the contaminants located? (Site Maps)
•   What contaminants were found over the criteria limits? (MDEQ Criteria Limits)
•   How high over the criteria are the concentrations of the contaminants?
•   Are there areas on the site where contaminants have high concentrations (hot spots)?
•   Are the contaminants in the soil or the groundwater?
•   Will the contaminants volatilize (evaporate)? (List of Volatiles)
•   Will the contaminants leach from the soil to the groundwater?
•   What are the health effects of these contaminants? (Health Effects)



3. Ensure the RAP addresses all relevant issues

•   Will the remedial action ensure that all relevant contaminants are addressed? (Remediation Technologies)
•   Are "hot spots" addressed?
•   Will all contaminant levels be reduced on site to meet the DEQ criteria? (MDEQ Criteria Limits)
•   Are there other cleanup methods available that are less expensive or more protective of human health? (Remediation Technologies)
•   Will the contaminants remain on the site after the implementation of the RAP?
•   Is the exposure of neighbors and workers during the cleanup addressed?



4. Confirm that there is continued protection of residents and workers

•   Will monitoring of the air, soil, or groundwater take place?
•   How will engineered controls (e.g., a site cap or geomembrane liners) be maintained or replaced?
•   Who is responsible for ensuring the protection of residents and the integrity of any engineered controls?
•   Who will pay for monitoring and maintenance?
•   Will there be permanent markers at the site or deed restrictions?
•   Is future building construction/maintenance considered?