The fourth step in MDA guidance document GD3 Seven Steps to a Historical Agricultural Chemical Cleanup entails submitting a Remedial Investigation Report/Corrective Action Plan (RI/CAP). For the RI/CAP, the environmental consultant will evaluate all information gathered during the site investigation and then discuss appropriate corrective actions with the client. Once this is completed, a RI/CAP will be submitted to the MDA for review and approval. This guidance document is designed to provide instruction for drafting an RI/CAP, and is divided into two sections: one for the RI report and one for the CAP, although these reports are usually submitted together as an RI/CAP.
The RI/CAP should clearly present the site history and background information, site investigation results, and how the contaminated soil and/or water will be addressed. The plan should adequately address impacts on and protection of public health and the environment. The RI/CAP must be approved by the MDA prior to carrying out any corrective actions. With MDA’s approval of the RI/CAP, corrective action costs for the site become eligible for reimbursement through the Agricultural Chemical Response and Reimbursement Account (ACRRA). See MDA guidance document ACRRA.001 Reimbursement of Costs for Agricultural Chemical Incident Cleanups: ACRRA.
All remedial investigation work should be completed in accordance with MDA guidance document GD9 Remedial Investigation and Work Plan. After the remedial investigation work is completed, an Agricultural Chemical Incident Remedial Investigation Report (RI Report) must be submitted to the MDA. (In situations when additional analysis or investigations are warranted, a limited or preliminary report of data may be submitted to the MDA prior to submitting the RI Report.) Although following the RI Report format is not required, MDA staff have the option to reject incomplete reports. If RI activities do not accomplish the RI objectives, additional activities and reports may be necessary.
The RI Report should be a comprehensive document. All data used in the remedial investigation, such as geologic logs, well construction logs, and laboratory data, should be reproduced in the appropriate tables and appendices, without reference to previous reports.
This section of an RI Report should address the following:
This section should contain:
This section should describe:
This section should discuss:
This section should summarize the findings of the investigation including:
This section should present:
The author's name, address, telephone number, signature, and date of signature should be in the RI Report.
All tables for analytical results should include numerical information such as the actual method detection limit (e.g.,“<0.1”) rather than “Not Detected” for those parameters not detected above the method detection limits.
This section should contain sufficient information to document all activities conducted during the investigation and corrective actions. All data must be legible. At a minimum, this information must include the following (when applicable):
All information requested in MDA guidance documents GD11 Soil Sampling Guidance and GD12 Ground Water Sampling Guidance.
The Corrective Action Plan (CAP) should present a sufficiently detailed plan of the proposed corrective action to permit evaluation of its likely effectiveness for remediation of the agricultural chemical incident. In addition, the CAP should provide a description of the proposed management practices to prevent future agricultural chemical incidents from occurring. The actual contents will vary according to the type of corrective action being proposed. The work proposed in the corrective action plan must comply with all local, state and federal regulations and ordinances.
In general, you should include the following in the CAP:
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