Investigation & Corrective Action Procedures

Investigation

When a contaminated site is transferred to the program, Orphan Sites Program staff review the available site information to determine the existence and source of contamination, whether there are affected or potentially affected health and environmental receptors, and calculate the site's score on the Contaminated Sites Ranking System. This system allows the program to prioritize the sites to ensure that contamination most threatening to human health and the environment is adequately addressed. If no previous investigation has been conducted, the investigation may be necessary to obtain enough information to rank the site. Contaminated sites typically proceed through one or more investigation phases including, but not limited to: site investigations, source investigations, comprehensive investigations, supplemental site or source investigations, the installation of monitoring wells, monitoring events, reviewing the site's history, and identifying any responsible parties.

Long Term Monitoring

Once an investigation is completed, if no responsible party is identified, the site will be evaluated and prioritized for corrective action activities. If conditions at the site require corrective action, but the site ranks low in priority, the site will be placed in Long Term Monitoring until funding for cleanup becomes available. If contamination conditions at the site do not require cleanup activities and do not yet meet reclassification criteria as described in KDHE policy BER-RS-024 (PDF), the site will be placed in LTM until such time that it meets reclassification criteria or conditions at the site warrant further KDHE response activities. Once a site meets reclassification criteria, the site will be reclassified as resolved and removed from the program.

Corrective Action

If no responsible party is found, and site conditions justify it, a Corrective Action Study (CAS) will be performed. The main objectives of the CAS are to evaluate the feasibility, effectiveness, and cost of at least two potential remedial actions based on the findings of investigations previously conducted at the site, and to evaluate the "no action" alternative. The CAS will also recommend and justify a specific corrective action for the site and determine the health and environmental effects of the remedial action.

Once the remedial action alternative is selected, the site will be prioritized among other Orphan Sites Program corrective action candidates. When funding becomes available, KDHE initiates corrective action activities for sites based on priority. Due to the elevated cost of corrective action activities, the Orphan Sites Program usually has the funding to conduct one to two smaller cleanups each fiscal year. Larger cleanups may require Orphan Sites Program funding over several years to conduct the cleanup.

Cleanup activities at a particular site may range from installing a pump and treat system on a contaminated well to addressing groundwater contamination, to stabilizing and/or removing contaminated soil. The program also designs and installs water lines and/or treatment systems to provide safe drinking water to residences with contaminated private drinking water wells.

Once cleanup activities have been completed, the site may be placed into KDHE's Long Term Monitoring program until the site can be reclassified as resolved and removed from the program.