Corrective Action Plans / Remedial Action Plans
Environmental CAPs & RAPs
Environmental contamination is addressed through a phased regulatory process. A Corrective Action Plan (CAP) and a Remedial Action Plan (RAP) serve different purposes and occur at different stages of investigation and cleanup. In Georgia, these are commonly referred to as CAP – Part A and CAP – Part B.
Georgia Oilmen’s Services (GOS) prepares both CAPs and RAPs to evaluate contamination, assess risk, and guide properties toward regulatory compliance and closure.
Corrective Action Plan (CAP Part A)
Corrective Action Plans (CAPs) contain the recommended steps for companies who have a confirmed contaminant discharge on their property. Included in the CAP is a detailed proposal outlining what technologies should be used and the estimated timeline for bringing a property into compliance.
By creating a CAP, GOS safely identifies the source of contamination and works to mitigate it so that further contamination does not occur.
Environmental CAP Process
The first step of the process when a confirmed release has occurred is to conduct a contamination site assessment, also known as a CAP – Part A in Georgia, which includes the installation of groundwater monitoring wells to determine the presence of contamination in soil or groundwater. The process also includes field investigations, data analysis, and reporting required by state environmental agencies to determine whether further corrective or remedial action is necessary.
Groundwater Monitoring Well Installation
As part of the CAP process, GOS installs groundwater monitoring wells in accordance with Georgia EPD and Florida DEP standards. During installation, soil and groundwater samples are collected and analyzed for petroleum constituents to evaluate the presence and extent of contamination.
- During installation of these wells, soil and groundwater samples are collected and assayed for the presence of petroleum constituents.
- A survey of potential receptors, including drinking wells, streams, and lakes, is conducted.
- An estimate of the direction of groundwater flow is calculated to determine whether contamination is likely to impact any of the potential receptors.
- If free product is detected during field activities, a program for recovery is immediately implemented with approval from the owner of the site. Initiating immediate free product recovery reduces the contaminant migration potential and can significantly reduce the final cost of the project.
Additional Included Information
Each CAP includes comprehensive documentation required for regulatory review, such as site maps, historical use information, contaminant characterization, and professional recommendations. This information establishes a clear environmental baseline and supports decisions regarding the need for further action.
Some components may include:
- Property description and site location map
- History of the site
- Description of the current contamination
- Recommended mitigation
Remedial Action Plan (RAP/CAP Part B)
A remedial action plan (RAP), also known as a CAP – Part B in Georgia, is often advised and/or required if contamination levels exceed applicable action levels. It is intended to be the final stage of contamination assessment. A RAP/CAP – Part B will detail the environmental impacts that are expected on a property.
Environmental Contamination Projection
It may include computer-generated groundwater contaminant fate, transport modeling, monitoring of the site or active remediation strategies for the contaminant plume. GOS strongly utilizes computer modeling to determine whether the contamination is projected to impact any nearby receptor(s).
Should groundwater modeling predict that no impact to potential receptors will occur, no remediation may be warranted, and only groundwater monitoring may be required.
Process Completion
Upon completion of the approved monitoring or remediation program, GOS evaluates site data to confirm stability and regulatory compliance. If contaminant concentrations remain stable or decline and no additional impacts are identified, a No Further Action (NFA) or equivalent regulatory closure status may be requested from the appropriate agency in Georgia or Florida.
Contact Us
If you need a Corrective Action Plan (CAP – Part A) or a Remedial Action Plan (RAP / CAP – Part B) for your property in Georgia or Florida, Georgia Oilmen’s Services is ready to help. Contact us today to schedule environmental services, discuss regulatory requirements, and begin the path toward compliance and closure.