Petroleum Cleanup Program

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Guide to Florida’sPetroleum Cleanup Program

Protecting Your Environment

Table of Contents

Introduction

Inclusion of specific equipment brands within this document is intended for information purposes only anddoes not constitute endorsement of these products.

This handbook is the result of a state and local government partnership between Florida’s Department ofEnvironmental Protection (DEP), Division of Waste Management, Bureau of Petroleum Storage Systems(www.dep.state.fl.us/waste/catagories/pss/default.htm) and Broward County’s Department of Planning andEnvironmental Protection (DPEP) (www.broward.org/dpep). The intent of the handbook is to provide a clearand concise presentation of the principals of petroleum contamination cleanup and the regulatoryrequirements found in Chapter 62-770, Florida Administrative Code. If you have questions or commentson this handbook, feel free to e-mail either DEP ([email protected]) or DPEP([email protected]).

Finally, both DEP and DPEP want to emphasize that this handbook is intended for information purposesonly, does not carry regulatory authority, and does not substitute for a thorough and professionalknowledge of Chapter 62-770 and associated requirements.

Why Florida has a Petroleum Cleanup Program ............................................................................................ 1History of Florida’s Cleanup Program ............................................................................................................. 2Petroleum Cleanup Program Statistics ............................................................................................................. 3Chemical Composition of Petroleum Products ............................................................................................... 4Sources of Petroleum Product Contamination and Their Impacts on the Environment .......................... 5The Cleanup Process ........................................................................................................................................... 7Proper Response to a Discharge ........................................................................................................................ 8Discharge Report Form ....................................................................................................................................... 8Source Removal ................................................................................................................................................. 10Standards ............................................................................................................................................................ 11Site Assessment .................................................................................................................................................. 12Active Remediation:

Introduction .................................................................................................................................................... 14Air Stripping ................................................................................................................................................... 15Soil Vapor Extraction ..................................................................................................................................... 16Air Sparging ................................................................................................................................................... 17Dual-Phase Extraction ................................................................................................................................... 18Bioremediation ............................................................................................................................................... 19Excavation and Treatment or Disposal ....................................................................................................... 20Chemical Treatment....................................................................................................................................... 21

Monitored Natural Attenuation ...................................................................................................................... 22Post Active Remediation Monitoring ............................................................................................................. 22Pay-for-Performance ......................................................................................................................................... 23No Further Action/No Further Action with Conditions ............................................................................. 24Risk Assessment ................................................................................................................................................. 25Time Line ............................................................................................................................................................ 26Key Points ........................................................................................................................................................... 28

1

Why Florida has a Petroleum Cleanup Program

Ninety percent of Florida’s drinking water comes fromseveral aquifers underlying the State, providing over 4.3billion gallons per day (Figure 1).

The purpose of the petroleum cleanup program is toprotect this critical environmental and economicresource from past and future petroleum releases.These releases occur for a variety of reasons includingaccidental spills, storage tank system leaks, and poormaintenance practices.

Groundwater, and any petroleum contamination in orfloating on it, is not static. It moves horizontallythrough the subsurface in several directions, in mostcases at a much slower rate than surface water. It alsomoves vertically with the continuous downwardpercolation of rainwater. In some places, aquifersoverlie other aquifers and there can be vertical flowbetween them (Figure 2).

In addition, the groundwater depth can fluctuatebetween wet and dry seasons, and in coastal areas mayfluctuate daily in response to tidal influences.

Florida has a diverse geology ranging from coastalsands, karst limestone, red clay marl, coral rock, organicpeat, and silts (Figure 3). Each of these soil types hasdifferent size soil particles and other physical andchemical properties and, as a result, will adsorb or trapcontaminants to varying degrees.

This combination of diverse geology, diverse hydrology,and variable physical and chemical dynamics betweencontaminants and environmental media makes theidentification and cleanup of petroleum contamination achallenging task. But, it is a necessary task if Florida isto protect this precious resource for current and futuregenerations.

Figure 1 - Principal Aquifers of Use

Figure 2 - Groundwater Flow

Figure 3 - Environmental Geology

2

History of Florida’s Cleanup ProgramThe Petroleum Cleanup Program

The State of Florida and the Florida Department of Environmental Protection (DEP) have been dealing with the problem of petroleumcontamination since 1984. Since that time numerous statutes, administrative rules, and guidance documents have established requirementsand procedures for petroleum storage system registration and compliance, for petroleum contamination assessment and remediation,and for programs that provide financial assistance for cleanup. The State of Florida no longer provides funding assistance fornewly reported discharges. The responsible party or parties and/or their insurance providers must bear the cost for anyrequired assessment and cleanup.

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Chapter 376, Florida Statutes (1984)

Inland Protection Trust Fund (1986)● Part of the State Underground Petroleum Environmental

Response (SUPER) Act● Authorized the DEP to establish criteria for the prioritiza-

tion, assessment and cleanup, and reimbursement forcleanup of petroleum contaminated sites.

● Established funding source for assessment and cleanup ofpetroleum contaminated sites, derived from a tax on

petroleum products produced in or imported into Florida● Funding assistance available in two formats:

1) State Cleanup conducted in priority order by a Statelead contractor, or

2) Reimbursement on a first come, first served basis forwork completed in accordance with FDEP rules

Early Detection IncentiveProgram (EDI) (1986)

● First State assisted cleanup program● 100% State funding for cleanup if

property owners report releases● Application period ended at the end

of 1988

Petroleum Liability &Restoration InsuranceProgram (PLRIP) (1989)

● Intended for active facilities● State underwrote the restoration

portion of insurance coverage for newdischarges, subject to various caps anddeductibles depending on discharge date

● State restoration coverage ended onDecember 31, 1998

Abandoned Tank RestorationProgram (ATRP) (1990)

● Created to address contamination atfacilities that were out of business as ofMarch 1990

● Application period ended in June 1996;however, the ATRP application window isopen indefinitely for property owners whoare unable to pay for the closure ofabandoned tanks

● 100% State funding (less deductible)

Preapproval Program (1996)● Legislation phased out the reimbursement format of funding assistance● All State funded cleanups would be conducted on a pre-approved basis, in priority order, and within the current fiscal year budget

Petroleum Cleanup ParticipationProgram (PCPP) (1996)

● Created to include sites that had missed allprevious opportunities for State assistance

● Only for discharges reported prior to 1995● Application deadline was the end of 1998● The responsible party must pay a percent-

age of cleanup costs and prepare a limitedscope assessment at their own expense

● Has cap on amount of coverage

Preapproved Advanced Cleanup(PAC) (1996)

● For sites already eligible in a State cleanupprogram other than PCPP

● Provides funding assistance out of priorityorder

● The responsible party must pay a percent-age of cleanup costs and prepare a limitedscope assessment at their own expense

● Has cap on amount of coverage

Free Product RecoveryInitiative (1999)

● For sites already eligible in a Statecleanup program

● Provides funding for the preapprovedremoval of free-phase petroleumproduct out of priority order.

● Instituted compliance and prevention measures for petroleum storage systems● Chapter 62-761, F.A.C., Stationary Tank Rule (New, May 1984)● Contaminated sites were discovered as new leak prevention measures were implemented

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Site Rehabilitation Agreements (1999)● Addresses new petroleum discharges (reported after 12/31/98) that are not eligible for state funded cleanup and that occur at sites with

existing contamination eligible for state funded cleanup.● Within 120 days the responsible party may submit an application together with a Limited Contamination Assessment Report to enter into a

negotiated agreement with the DEP to share in the cost and to coordinate the timing of a combined cleanup.

3

61%

39%

Underground Tanks

Above-Ground Tanks

52,196 Active RegisteredPetroleum Storage Tanks

at 20,097 Facilities

Ineligible for State Funding AssistanceBoth Eligible and Ineligible Discharges

Eligible for State Funding Assistance

22,318 Sites with ConfirmedPetroleum Contamination

79%17%

4%

54%

46%

14,927 Eligible Sites(Awaiting Cleanup or

in Progress)

Sites with Cleanup Underway

Sites Awaiting Cleanup

46%

29% 25%

Awaiting CleanupCleanup UnderwayCleanup Complete

22,318 Sites with ConfirmedPetroleum Contamination

Florida’s storage tank registration program and therequirement to report discharges helps identifycontaminated sites. After prioritizing sites byassigning scores based upon health threats, cleanupbegan with the highest risk sites and is proceedingtoward those sites that pose a lessor risk to humanhealth and the environment.

Scoring Range of Petroleum Discharges

0-910-19

20-2930-39

40-4950-59

60-6970-79

80-8990-99

>1000

1000

2000

3000

4000

Distribution of Eligible Discharge Priority Scores*

Nu

mb

er o

f D

isch

arg

es

5000

3,174

4,613

1,543 1,893

786

1,558

1,2041,431

476 219 107

The priority score for a petroleum site establishes asite’s place in line for cleanup with State funds orpriority for enforcement action. The priority scorerepresents the relative threat the site poses topotential receptors. The higher the score, the greaterthe potential threat.

*Note: December 2001 Data*Note: February 2002 Data

Program Statistics*

Petroleum Cleanup Program Statistics

For more information, see the DEP Bureau of Petroleum Storage Systems website at:www.dep.state.fl.us/waste/catogories/pss

Implementation of Florida’s Petroleum CleanupProgram is the responsibility of DEP’s Bureau ofPetroleum Storage Systems located in Tallahassee. TheBureau contracts 15 contracted local county orDepartment of Health environmental programscovering 23 counties throughout the state to assist in themanagement and oversight of individual cleanups.

Escambia Walton

SantaRosa

Okaloosa

Broward

Orange

Hillsborough

Bay

Miami-Dade

Pinellas

Brevard

Seminole,including Lake

Volusia

AlachuaDuval

PalmBeach

Collier

Sarasota

Polk, includingHardee, Highlands,

and Osceola

Unde

r one contract with Escambia County

Contracted Local Programs

4

Chemical Composition of Petroleum Products

▲ When petroleum products, or the waste associated with use of these products, are released into theenvironment, they chemically and biologically interact with the soil, groundwater, and microorganisms.

▲ The ratios of these chemicals serve as a fingerprint for the type of product (diesel, gasoline, etc.)originally released into the environment.

Chemical Symbol Human Toxicity

Probable carcinogen (cancer-causing agent), CentralNervous System (CNS) depression, Irregular heart rhythm

Abdominal pain, vomiting; CNS effects; Heart and liverdamage; Bone marrow damage

Mutagenic (causes mutations), CNS depression, Respiratoryirritation, Liver, kidney damage

Narcosis, CNS effects, Skin and eye irritation

Abdominal Pain, Jaundice, Renal failure, Optical neuritisand corneal damage

General Class with varying degrees of toxicity, several ofwhich are potential carcinogens. 17 specific PAHs areregulated under Florida’s Petroleum Cleanup Program

Varying degrees of toxicity. Arsenic is a carcinogen and hasreproductive effects. Lead can cause kidney disease,malnutrition, and weakness.

MTBE (Methyl Tertiary Butyl Ether) is a fuel additive which has been used in the United States since 1979. Itsuse began as a replacement for lead in gasoline because of health hazards associated with lead. MTBE hasdistinctive physical properties that result in it being highly soluble, persistent in the environment, and able tomigrate through the ground. DEP has required the monitoring and cleanup of MTBE at petroleum contaminatedsites since February, 1990, and continues to monitor studies focusing on the potential health effects of MTBE andother fuel additives. For more information, visit DEP’s Petroleum Cleanup Program web site at:www.dep.state.fl.us/waste/catagories/pcp.

Oil

ProductSpecific

RefinementProcess

Furnace

DefractionColumn Lighter

Products

HeavierProducts

PetroleumCrude

Common Petroleum-based Products

●●●●● Gasoline

●●●●● Diesel Fuel

●●●●● Aviation Fuel (Kerosene)

●●●●● Oils and Lubricants

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Some of the chemicals found in petroleum products,significant because of their toxicity or their taste and smell are:

5

Sources of Petroleum Product Contamination andTheir Impacts on the Environment

Common SourcesThe most common sources of petroleum contaminationfrom stationary petroleum storage systems are:

• leaks in piping and joints,• leaks from corroded tanks, and• various equipment failures upon startup of

newly installed storage systems,• overfills and spills while filling tanks.

When released to the environment, petroleum andpetroleum products can contaminate:

• Soil• Groundwater• Surface water• Air

Contaminant PlumesThe type, amount, and duration of the discharge, thelength of time elapsed since the discharge, and thehydrogeologic conditions underlying the site, willdetermine the size, length, and depth of the

contaminant plume. Many factors will determine howquickly a plume will migrate, including:

• Groundwater flow rate• Adsorption (adherence) to soils• Dispersion• Biodegradation (microbes using the

contaminant as food)• Volatilization (vaporization of contaminants)• Preferential pathways through highly

permeable zones and channels.

Because petroleum is lighter than water, free(undissolved) product and most dissolvedcontamination is usually concentrated near the top ofthe groundwater table. As the water table rises and fallswith seasonal variations and drought or floodconditions, contaminants concentrate in smear zonesabove and below the mean water table. Adequatelytreating these smear zones plays a key role in theremediation process.

GROUNDSURFACE

AQUIFER

WATERTABLE

Volatilization

PetroleumStorage Tank

Free Product

DissolvedHydrocarbons

Biodegradation

Smear Zone

DissolvedHydrocarbon Plume

Expanded View of Free ProductTrapped in Pores Between Soil and

Sediment Particles

FreeProduct

SorbedContaminants

VaporSolid Water

Dispersion and Dilution

Free Product

PetroleumHydrocarbonLeak

6

Sources of Petroleum Discharges and Their Impact on the Environment (continued)

Threats from Contaminants in the EnvironmentThough relatively rare, explosive vapors fromdischarged petroleum products can accumulate inconfined spaces such as an abandoned tank, asubsurface cable vault, in sewer pipes or beneathbuildings. Ignition of these vapors can cause anexplosion with potentially catastrophic results.Human exposure to petroleum contaminants can occurthrough:

• Ingestion of contaminated drinking water andsoil residues,

• Inhalation of vapors and airborne soils,• Contact of contaminants with skin (dermal

exposure).Health impacts of exposure to petroleum contaminationmay include skin and lung irritation, headaches,dizziness, fatigue, diarrhea, cramps, and nervoussystem effects. Benzene and other chemicals found inpetroleum products have been determined to becarcinogenic (cause cancer). Chronic (long-term)exposure to contaminants by ingestion and inhalationwas considered in the derivation of the petroleum

cleanup target levels referenced in Chapter 62-777,Florida Administrative Code (F. A. C.) discussed furtheron page 11.

More information regarding toxicity of petroleumchemicals is available from the Agency for ToxicSubstances and Diseases Registry, an agency of the U.S.Department of Health and Human Services. Theirhomepage address on the world wide web iswww.atsdr.cdc.gov.

Petroleum contamination may also cause adverseimpacts to nearby plants and animals, from the smallestto the largest members of the natural food chain. Plantsgrowing in contaminated soils or water may die orappear distressed. Animals may drink contaminatedwater or feed upon plants or other animals which havebeen exposed to contaminants. Although not visible tothe naked eye, subsurface elements of ecosystems, suchas microorganisms, may be overwhelmed bycontaminants. Sensitive habitats, such as wetlands andmarine ecosystems, are particularly susceptible topetroleum chemicals.

LEAKINGTANK

LEAKINGBARRELS

LEAKINGGASOLINE

HAZARDOUSVAPORSIN SOIL

DEAD OR DYINGTREES AND PLANTSHUMAN EXPOSURE

TO CONTAMINATEDSOIL AND

GROUNDWATER

PICTURE OFEXCAVATION WITHGROUNDWATERCONTAMINATED

WATER TABLEWATER TABLECONTAMINATED

DRINKING WATERWELL

7

The Cleanup Process

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Discovery ofDischarge

ReportingRule 62-770.250, F.A.C.

SourceRemoval

Rule 62-770.300, F.A.C.

SiteAssessment

Rule 62-770.600, F.A.C.

ActiveRemediation

Rule 62-770.700, F.A.C.

RiskAssessment

Rule 62-770.650, F.A.C.

MonitoredNatural AttenuationRule 62-770.690, F.A.C.

No Further Action (NFA)or

No Further ActionWith Conditions (NFAC)

Rule 62-770.680, F.A.C.

Post ActiveRemediationMonitoring

Rule 62-770.750, F.A.C.

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The DEP has a program rule, called the Petroleum Contamination Site Cleanup Criteria, whereby the assessment andremediation of petroleum contamination sites must be performed. Established in Chapter 62-770, F.A.C., this rule isintended to provide a detailed, step-by-step process by which petroleum-contaminated sites are to be assessed andcleaned, from the time that a petroleum discharge or petroleum contamination is discovered to the time that the DEPgrants site closure (No Further Action or No Further Action with Conditions). The flow chart below demonstrates thesteps which may be involved in the cleanup process.

8

Proper Response to a DischargeRule 62-770.250, F.A.C.

ReportingA discharge of petroleum (or petroleum product) mayoccur or be discovered in a variety of ways. Reportingto the DEP or a contracted local program is required forthe following:

• Analytical or field tests of surface water,groundwater, or soils which exceed applicablestandards, or

• A spill or overfill event of a quantity greaterthan 25 gallons, or

• A spill or overfill event of less than 25 gallonson a previous surface unless immediatelyexcavated, or

• Visual observation of free product or sheen insurface water, groundwater, soils, basements,sewers, and utility lines at the facility or in thesurrounding area, or

• Visual observation of contamination duringsuch activities as compliance inspections andtank closure or upgrade activities, or

• Detection of free product in monitoring wells.Upon discovery that petroleum product has beenreleased into the environment, notification must be

provided by the discharger using a Discharge ReportForm (DRF). If the discharger is unknown, or if aunreported past discharge is discovered, the DRFshould be submitted by the facility owner or operator. ADRF does not have to be submitted for a previously-known and reported discharge.If the discharge was from a regulated storage tanksystem, the DRF must be delivered or faxed to theCounty tank compliance program or the DEP Districtoffice within 24 hours of discovery, or before the close ofthe next business day. For all other discharges ofpetroleum or petroleum product, the discharge must bereported within one week of discovery.

Additional NotificationOil spills to navigable waters must be reported withinone hour to the National Response Center or the FloridaMarine Patrol. Spills that are not to navigable waters,but pose an immediate threat to human health or theenvironment, must be immediately reported to the StateWarning Point or the Local Fire Department.

National Response Center: 1-800-424-8802State Warning Point: 1-800-320-0519Florida Marine Patrol: 1-800-342-5367

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DISPENSERS

UNDERGROUNDPIPING

UNDERGROUNDFUEL STORAGE TANKS

CONCRETEFOUNDATION

LEAKING FUEL

9

10

Source RemovalRule 62-770.300, F.A.C.

Soil Removal, Treatment,and Disposal

If contaminated soil exists at a site, excavation ofcontaminated soil for proper treatment or properdisposal may be performed. The DEP encourages thetreatment of contaminated soils over disposal. Theexcavation, treatment or disposal of contaminated soilmay be performed prior to regulatory approval underspecific conditions, including:

• Contamination is not spread into previouslyuncontaminated areas,

• Flammable products are handled in a safemanner,

• Excavated and stockpiled soils are secured in amanner that prevents exposure of contaminatedsoil to receptors and precipitation,

• The excavation pit is secured to preventaccidental or intentional entry by the public,

• Excavated soil is not to be stored or stockpiledon site beyond certain time limits.

• Contaminated soil is treated or disposed of inaccordance with applicable DEP and local rulesand regulations.

Source Removal ReportWithin 60 days of completion of:

• free product removal and proper disposal

• soil treatment or proper soil disposal

two copies of a Source Removal Report must besubmitted to the DEP or the contracted local programfor review.

Free Product Recoveryand Disposal

When released in the subsurface, petroleum may formfree floating product on top of the water table and canact as a continuing source of contamination. If freefloating petroleum product (in excess of 0.01 footthickness) is discovered at a site, the responsible partymust take steps to obtain cleanup services for productrecovery or initiate product recovery within three days.These requirements only apply to discharges which arenot eligible for financial assistance through the DEPPetroleum Cleanup Program. For Program-eligibledischarges, free product does not have to be removedprior to the time that assessment and remediationactivities are performed in priority order. However,State funding assistance may be sought for free productrecovery out of priority order through the “Free ProductRecovery Initiative” (See page 2).

Free product may be recovered without prior regulatoryapproval using one of the following methods:

• Absorbent pads• Skimmer pumps• Hand or mechanical bailing; and• Vacuum pump trucks or total fluid

displacement pumps, as long as specificrequirements are met.

Other recovery methods must be evaluated, proposed,and submitted to DEP or the contracted local programfor approval prior to implementation. Within 10 daysafter initiation of product recovery, written notificationmust be provided to DEP or the contracted localprogram for review. Free product recovery shouldcontinue until as much free product has been removedas practicable.

Tank and contaminated soil removalBailer containing petroleum free product

11

Standards

To determine the degree and extent of contamination, the analytical results of soil, groundwater, andsurface water samples are compared to applicable State standards. For the petroleum cleanup program,the standards are located in Chapter 62-777, F. A. C. These standards are also used to determineappropriate cleanup goals at contaminated sites. The standards represent the maximum allowableconcentration of contaminant allowable in the environment and are based on toxicity evaluation of bothcarcinogenic (cancer-related) and non-carcinogenic effects, as well as considerations of taste and odor.

Groundwater criteria arebased on health and

nuisance criteria(formulas can be found in

Rule 62-777. F.A.C.)

Note that there are separate tables for

soil and water

The maximum amount of contaminantallowable in soil subjected to residential uses

(Note: These levels must be met unless theproperty deed is restricted to prohibit

residential use.)

That amount of contaminant present in the

soil that would leach into water and result

in water contamination equal to thoseconcentrations referenced in Table 1

The maximum amount

of contaminant allowable

in soil subjected to

commercial/industrial uses

Both direct exposure and

leachability cleanup target levels

must be met for each chemical

mg/kg means parts per million (ppm)

ug/L means parts per billion (ppb)

12

FLOATINGHYDROCARBON LAYER

GROUNDWATER CONTAMINATEDWITH DISSOLVED HYDROCARBON

DIRECTION OF GROUNDWATER FLOW

WATERTABLE

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MONITORING WELLCONSTRUCTION

MONITORING WELLCOVER

MONITORING WELLCONTAINMENT

CONCRETE/GRADE

LOCKING CAP

VENT HOLE1/4”-8/8”

FACTORY SLOTTED(0.0.20 SLOTS)

4” DIA. SCH 40PVC PIPE

BENTONITESEAL

WATER

LEVEL

WATER

LEVEL

SAND PACK ORPEA GRAVEL

8” DIA.BORED HOLE

CAP

5 F

EE

T B

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W

WAT

ER

TAB

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FE

ET

BE

LOW

WAT

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TAB

LE

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RE

TH

AN

40’

CONTAMINATIONADSORBED ONTO SOIL

LIGHT INDICATOR

REEL

CASING

ELECTRICCABLE

ELECTRODE

WATER

LOCATION OF

LEAKING TANKFORMER

Site AssessmentRule 62-770.600, F.A.C.

The primary objectives of a site assessment are to:

✔ Characterize the surface and subsurface geology,soil lithology, and hydrogeology of a site,

✔ Determine the horizonal and vertical extent ofcontamination in soil, groundwater, and surfacewater, and

✔ Assess the potential threats of contamination tohuman and ecological receptors.

Many tools may be used by trained and certifiedpersonnel to accomplish the site assessment.

A. Monitoring Wells◆ Installed using specific and required construction

techniques.

◆ Used to define the vertical and horizontal extent ofa groundwater contaminant plume.

◆ Used as permanent points for groundwatersampling and analysis.

◆ Also used to monitor groundwater table depthand direction of groundwater flow.

B. Water Level Indicator◆ Used to determine the depth to site groundwater

inside a monitoring well.

C. Direct Push Rig◆ Push or hammer tools, sensors, and sampling

devices into the subsurface.

◆ Used to quickly obtain continuous soil cores or soiland groundwater samples to determine lithologiesand petroleum content.

◆ Used to install pre-packed microwells or todetermine the most appropriate monitoring welllocations and depths.

◆ Usually used with a FID or field GC/MS

D. Hand Auger◆ Tool used to collect surface and shallow subsurface

soil samples.

A

CD

B

13

FLOATINGHYDROCARBON LAYER

GROUNDWATER CONTAMINATEDWITH DISSOLVED HYDROCARBON

DIRECTION OF GROUNDWATER FLOW

WATERTABLE

CONTAMINATIONADSORBED ONTO SOIL

LOCATION OFFORMER LEAKING

TANK

E. Drill Rig◆ The most common types use a hollow stem

rotating auger or a rotary drill bit to penetrate thesubsurface.

◆ Used to collect information on subsurfacelithologies and petroleum content.

◆ Used in the installation of permanent groundwatermonitoring and recovery wells.

◆ Usually used with a FID or field GC.

F. Flame Ionization Detector (FID)◆ Hand-held instrument which provides a quick

assessment of hydrocarbon content in samples

◆ Type of Organic Vapor Analyzer (OVA)which detects compounds by burning them in ahydrogen flame.

◆ Used to cost-effectively screen a site for soil andgroundwater contamination to determine whichsamples should be collected and then analyzed inthe laboratory .

G.Gas Chromatograph (GC)◆ Used to detect and quantify contaminants in

samples while in the field.

◆ Should be correlated and corroborated with fixed-laboratory results.

H. Peristaltic Pump

◆ May be used to collect groundwater samples fromdedicated monitoring wells.

Site Assessment, (continued)

E

F G H

14

Active RemediationRule 62-770.700, F.A.C.

IntroductionOnce the full extent of contamination has been determined through a complete site assessment, several optionsmay be available to address or cleanup the contamination. The decision to use a remediation strategy in order to“actively” clean up contamination at a site may depend on one or more of several factors, including:

◆ Concentrations of contaminants in site soil and groundwater (see Standards, page 11).

◆ Proximity of the contamination to potential exposure routes such as drinking water wells and surfacewater bodies.

◆ Current and projected future use (including sale or development) of the property.

◆ Liability associated with contaminant migration and impacts to surrounding property.

Many different types of remediation equipment and strategies have been developed in order to cleanuppetroleum contamination. Some remediation technologies are designed to clean up contamination in either soilor groundwater; others are designed to address both. Prior to construction and/or implementation, a RemedialAction Plan (RAP) must be approved by DEP or the Contracted Local Program. The RAP must be certified by aFlorida Professional Engineer and must propose and justify the use of a particular remediation strategy. Pilottests (short-term field studies) may be conducted to develop the remediation strategy or design proposed in theRAP. Design overviews of the following remediation technologies are featured in this brochure:

Although widely used, the technologies featured in this brochure are only a few of the remediation strategieswhich are currently available to cleanup contaminated sites. The cost associated with these technologies varieswidely, and the applicability and effectiveness of any remediation technology is dependent upon many site-specific characteristics. By discussing these technologies, DEP does not express or imply that thesetechnologies are preferred over others which may be available or that one of these technologies is the mosteffective or appropriate strategy for cleaning up a particular contaminated site.

Air Stripping

Air Sparging/Soil Vapor Extraction

Bioremediation

Excavation and Treatment or Disposal

Chemical Treatment

15

Active RemediationAir Stripping (Pump and Treat)

Air Stripping

Air stripping is a treatment process wherebycontaminated groundwater is pumped from thesubsurface and then exposed to a flow of air. Bygreatly increasing the surface area of contaminatedwater exposed to air, dissolved volatile chemicals areremoved from the water and transferred to the air.

The typical packed tower air stripper (shown above)includes a spray nozzle at the top of the tower todistribute contaminated water over packing in thecolumn, a fan to force air countercurrent to the waterflow, and a sump at the bottom of the tower to collecttreated water. Contaminants in the air stream are eitherdischarged into the atmosphere or captured.Discharged vapors must meet Federal EPA air dischargestandards or they must be treated. Treated water iseither returned to the groundwater via an infiltrationgallery or discharged to sanitary sewer, storm water, orsurface water bodies. As a final step prior to rechargeor discharge, the water is often pumped through aseries of canisters or columns containing granularactivated carbon (GAC), a material which adsorbs

residual dissolved organic contaminants.

Other types of aeration equipment include the diffusedaerator, spray aerator and tray stripper. The low-profiletray stripper (shown above left) is a unit consisting of anumber of trays packed into a very small chamber tomaximize air-water contact while minimizing space.

Typical air stripping equipment includes speciallydesigned groundwater recovery wells and pumps, oil/water separators, blowers, tower or tray strippers,transfer pumps, GAC canisters, equipment controllers,infiltration galleries, piping networks, valves, waterflow meters, and manifolds. Auxiliary equipment thatcan be added to the basic air stripper system includes anair heater to improve removal efficiencies; automatedcontrol systems with sump level switches and safetyfeatures, such as differential pressure monitors, highsump level switches, and explosion-proof components;and air emission control and treatment systems, such asactivated carbon units, catalytic oxidizers, or thermaloxidizers.

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MIST ELIMINATOR

POLYPROPYLENEPACKING

CONTROLPANEL

EQUIPMENTCOMPOUND

SPRAY DISTRIBUTIONNOZZLE

CONCRETEBASE

VALVES

BLOWERMOTOR

OBSERVATION/CLEAN OUTPORT

PRESSUREGAUGEINFLUENT

SAMPLEPORT

CHECKVALVE

RECOVERY WELLWITH PUMP

CLEANOUTPIPE

COARSE ROCKFILL

PERFORATEDMETAL PIPING

FILTERCLOTH

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INFILTRATIONGALLERY

CARBONCANISTERS

AIR STRIPPERASSEMBLY

CONTAMINATEDGROUNDWATER

Low-profile TrayStripper

16

Active RemediationSoil Vapor Extraction

Soil Vapor ExtractionSoil vapor extraction (SVE) is the process of applying avacuum to soils located above the water table (thevadose zone) causing a controlled flow of air tovolatilize and remove contaminants trapped in the soilor product floating on top of the water table. Thevacuum is applied through vertical or horizontalextraction wells. Volatile contaminants exiting the soil inthe gas stream are usually recovered using granularactivated carbon (GAC) adsorption canisters (as shownabove) and/or treated using a thermal oxidizer, acatalytic oxidizer, or a combustion engine.

Typical equipment includes specially designed vaporextraction wells, water condensation tanks, transferpumps, blowers, thermal oxidation or vaporcombustion units, equipment controllers, GACcanisters, piping networks, valves, vacuum gauges, airflow meters, and manifolds. The effectiveness of SVEmay be improved by injecting air into vadose zone soilsor by covering the overlying soil surface with ageomembrane. Groundwater depression pumps mayalso be used to reduce groundwater upwelling inducedby the vacuum or to increase the depth of the vadosezone.

Off-gas Treatment:Vapor-phase Carbon Adsorption System

Vapor-phase carbon adsorption is a remediationtechnology in which pollutants are removed fromextracted vapors by physical adsorption onto activatedcarbon grains. Carbon is “activated” for this purpose byprocessing the carbon to create porous particles with alarge internal surface area that attracts and adsorbscontaminant molecules. Granular-activated carbon(GAC) systems typically consist of one or more vesselsfilled with activated carbon connected in series and/orparallel.

Off-gas Treatment:Thermal/Catalytic Oxidation

Oxidation equipment may also be used for destroyingcontaminants in the exhaust gas from air strippers andSVE systems. Thermal oxidation units destroycontaminants in a high-temperature combustor (seeinset above). Catalytic oxidation accelerates the rate ofcontaminant destruction by adsorbing oxygen and thecontaminant onto the catalyst surface where they react,destroying the contaminant. Trace concentrations ofchemicals in contaminated air streams are destroyed atlower temperatures in catalytic oxidation units thanthose used in thermal oxidation. Thermal and catalyticoxidation units are typically single chamber unitsmounted on a trailer or skids, equipped with a propaneor natural gas burner and stack.

CONCRETE FOUNDATION

HORIZONTALVAPOR

EXTRACTIONWELL

VENT TOATMOSPHERE

GAUGEBLOWERMOTOR

CARBONCANISTERVALVE

DRAINVALVE

VERTICALVAPOREXTRACTIONWELL

CONCRETEFOUNDATION

HORIZONTAL VAPOREXTRACTION WELL

CONTAMINATEDSOIL

Thermal/CatalyticOxidation Unit

17

Active RemediationAir Sparging

Air Sparging (with Soil Vapor Extraction)

Air sparging is the process of injecting air through acontaminated aquifer to agitate and volatilizecontaminants dissolved in the groundwater or trappedin smear zone soils. The injected air flushes (bubbles)volatile contaminants into soils above the water table(the vadose zone), where a soil vapor extraction (SVE)system is usually implemented to remove and recoveror treat the generated vapor phase contamination (seepage 16 for an explanation of SVE and off-gastreatment).

Another benefit of air sparging technology is that theoxygen added to contaminated groundwater andvadose zone soils can also enhance aerobicbiodegradation of contaminants below and above thegroundwater table (see page 19 for an explanation ofbioremediation).

Typical equipment, in addition to that used for SVE,includes specially designed air sparge wells, blowers,piping networks, valves, pressure gauges, air flowmeters, and manifolds.

CONCRETEFOUNDATION

VAPOREXTRACTION

WELL

COMPRESSORCARBONCANISTER

AIRSPARGEWELL

SOIL

MONITORINGWELL

CONTAMINANTVAPOR

AIR

SOIL VAPOR MONITORING

DRAINVALVE

VAPOREXTRACTIONWELL

BLOWER


VENT TOATMOSPHERE

18

Active RemediationDual-Phase Extraction

RECOVERYWELLS

INLET FILTER▼

DISCHARGESILENCER PARTICULATE

FILTER

CARBON VESSELS

STACK TOATMOSPHERE

VENT TO ATMOSPHERE

AIR STRIPPER

CONTROL PANEL

AIR STRIPPERBASE

BLOWERMOTOR

PORTABLE SKID

CONCRETE FOUNDATION

DISCHARGE TOINFILTRATION GALLERY

VACUUMPUMP

LIQUIDLINE

TRANSFERPUMP

BLEED AIRDILUTION

VALVE

BALLVALVE

MOISTURESEPARATOR

CONTAMINANTVAPORS

CONTAMINATED GROUNDWATER

VAPORLINE

Dual-Phase Extraction

Dual-Phase Extraction (DPE), also known as multi-phase extraction, is a technology that uses a highvacuum system to simultaneously remove variouscombinations of contaminated groundwater, free-phasepetroleum product, and hydrocarbon vapor from thesubsurface. In DPE systems for liquid/vapor treatment,vacuum extraction wells are screened over the zones ofcontaminated soils and groundwater and, therefore,remove contaminants from above and below the watertable. The vacuum lowers the water table around theextraction wells, making newly exposed vadose zonesoils accessible to vapor extraction. Once above ground,the extracted vapors or liquid-phase organics and

groundwater are separated and treated (see Off-GasTreatment, page 16, and Air Stripping, page 15).

DPE for liquid/vapor treatment is often combined withbioremediation (see page 19) and/or air sparging (seepage 17). Use of dual phase extraction with thesetechnologies can shorten the cleanup time at a site. Anoil/water separator is typically used in DPE systemswhich are applied to sites which have free-phasepetroleum product. Typical equipment for DPE alsoincludes specially designed extraction wells, acondensation tank, an air stripper, a vapor treatmentunit, Granular Activated Carbon (GAC) canisters,piping, pressure gauges, air flow meters, and valves.

19

Active RemediationBioremediation

Bioremediation

Aerobic biodegradation is the natural process of themetabolic breakdown of contaminants by micro-organisms into less harmful components. Underoptimum physical, chemical, and biological conditions,the natural population of subsurface microorganismsmultiplies rapidly and uses petroleum contamination asa food source, leaving the harmless by-products ofadditional microbial growth, carbon dioxide, and water.However, success often is limited by the lack ofsufficient oxygen for microorganisms in thecontaminated zones. Bio-remediation is a process thatattempts to create such optimum conditions byintroducing essential nutrients and air or anotheroxygen source to the contaminated area in order toenhance the natural population of microorganisms.

During hydrogen peroxide enhancement, a dilutesolution of hydrogen peroxide is circulated through thecontaminated groundwater zone to increase the oxygen

content of groundwater and enhance the rate of aerobicbiodegradation of organic contaminants by naturallyoccurring microbes. Air sparging below the water tablealso increases groundwater oxygen concentration andenhances the rate of biological degradation of organiccontaminants by naturally occurring microbes (see page17 for an explanation of air sparging). Bioremediationmay also be accomplished by introducing bacteriawhich have been specialized to thrive on particularcontaminants. Although more expensive, it is possibleto create external (above-ground) treatment processesfor soil or groundwater that provide a more controlledenvironment and more predictable results.

Typical equipment varies. Most subsurface applicationsinvolve introduction points for the oxygen source andnutrients and some form of slurry or solution deliveryapparatus involving mixers and pumps.

Former UST

Ground Surface

SourceTreatmentin Tank Pit

Source Treatmentin Saturated Zone

Injection Wells

Oxygen Slurryand/or NutrientDelivered

Dissolved PhaseHydrocarbonPlume

Aerobic Microorganismseat oil or other organic

contaminants

Microorganismsgive off CO2

and H2O

Microorganisms digest oil andconvert it to carbon dioxide

(CO2) and water (H2O)

20

Active RemediationExcavation and Treatment or Disposal

Excavation and Treatment or Disposal

As an alternative to the previously describedtechnologies which treat soils without removing them,contaminated soils are often excavated and then treatedor disposed. Most often excavated soils are treated at acommercial soil thermal treatment facility or disposedin a permitted, lined landfill. Depending on site-specificcircumstances, these activities may be conducted as asource removal (see page 10). Other alternatives fortreating excavated soils include technologies such asbioremediation and soil washing. DEP preferstreatment methods over disposal methods forcontaminated soil.

Otherwise referred to as “dig and burn,” contaminatedsoil may be excavated and transported to a permittedthermal treatment facility, where it is exposed to high

temperature for a sufficient amount of time to volatilizeand fully combust the contaminants. The rotary kiln isa slightly-inclined, rotating cylinder that serves as acombustion chamber and operates at temperatures upto 980 °C (1,800 °F). Often auxiliary fuels are employedto initiate and sustain combustion. Exiting gasesrequire treatment by an integrated air pollution-controlsystem to destroy volatile hydrocarbon vapors, removeparticulates, and neutralize and remove acid gases.

Typical equipment for soil excavation includesexcavators, loaders, and dump trucks. Commercialthermal treatment systems are typically kilns equippedwith an afterburner, a quench, and an air pollutioncontrol system.

21

LIQUIDPUMP

CHEMICALSTORAGETANK

CONCRETEFOUNDATION

CHEMICALSLURRY


SOILSOIL

Active RemediationChemical Treatment

Chemical Treatment

Though there are many types of chemical treatments,the chemicals most typically used to destroy petroleumcontaminants in soil and groundwater are oxidants.Oxidants chemically breakdown hydrocarbon moleculesinto harmless ones, like water and carbon dioxide. Themost common oxidants authorized for use under certainconditions are hydrogen peroxide, permanganates, andozone.

At some sites, a catalyst is used with the oxidant. Acatalyst is a chemical that increases the strength orspeed of a process. For instance, if hydrogen peroxide ismixed with an iron catalyst, it produces a strongchemical called a free radical. Free radicals can destroymore harmful chemicals that hydrogen peroxide alone.The following equation demonstrates this particularoverall process:

Typical equipment used for the application of oxidantsto contaminated soils and groundwater is similar to thatfor bioremediation. Introduction points or wells areused to pump a chemical slurry or solution into theground. Ex-situ (above ground or external) equipmentcan involve holding cells, tanks, conveyor belts, pumps,mixers, sprayers, and piping networks with valves andmanifolds.

Tank and control equipment storedinside trailer

Injection lines leading from the trailerinto the subsurface.

Hydrogen Peroxide (H2O

2) and Hydrocarbon

Contaminant (CnH

x ) in the presence of iron catalyst

(Fe2+) makes Water (H20) and Carbon Dioxide (CO

2)

H2O2 + CnHx Fe2+ H20 + CO2

22

Monitored Natural AttenuationRule 62-770.690, F.A.C.

Natural attenuation refers to natural processes whichmay contain the spread of contamination and reducecontamination in groundwater and soil to acceptablelevels. These natural processes include:

• diffusion,• dispersion,• volatilization (contaminants exiting soil and

groundwater as vapor),• biodegradation (naturally-occurring microbes

break down contaminants),• adsorption (the binding of contaminants to soil

particles), and• chemical reactions with subsurface materials.

Natural attenuation is not the same as “no action.”Monitoring of contamination is required on a regularschedule to ensure that the reduction of contaminationis proceeding at rates consistent with meeting cleanupobjectives. However, the use of monitored naturalattenuation has some advantages when compared toother remediation strategies; it generates lessremediation wastes, is less intrusive and allows the site

to remain in productive use, and, in many cases, itrequires less overall cost.

The use of exclusive monitored natural attenuation isclearly not appropriate for every contaminated site.Monitored natural attenuation may only be used at siteswhich meet certain requirements, including:

• The contamination will not pose anunacceptable risk to human health or theenvironment,

• Free product and contaminated soil have beeneffectively removed from the site. Otherwise,the rate at which contamination continues toleach into groundwater may exceed the rate atwhich natural processes can attenuate thegroundwater contamination,

• Groundwater contaminant plumes are stable ordecreasing in size and are not migrating,

• Groundwater and Soil Cleanup Target Levels(Rule 62-777, F.A.C.), are expected to beachieved in a reasonable period of time.

Post Active Remediation MonitoringRule 62-770.750, F.A.C.

When groundwater contamination appears to have metthe applicable cleanup target levels for No FurtherAction criteria (see No Further Action, page 24), use ofan active remediation system may be discontinued.Following the discontinuation of an active soil orgroundwater remediation system, groundwatermonitoring must be performed for a minimum of one(1) year (unless contamination was only present in theunsaturated zone).

The purpose of post active remediation monitoring is toensure that contaminant concentrations do not reboundabove applicable standards. Even if groundwater

standards are met when a system is active,contamination may desorb from subsurface soilparticles and continue to contaminate groundwateronce the system is inactive. In the event thatcontaminant concentrations do increase beyondacceptable levels, the remediation system may need tobe reactivated. For this reason, it may be necessary forremediation equipment to be maintained and remainoperational during post active remediation monitoring.

If applicable standards are still met after the requiredpost active remediation monitoring period is complete,a site may be eligible for No Further Action.

Aerobic Microorganismsconsume oil or otherorganic contaminants

Microorganismsgive off CO2

and H2O

Microorganisms digest oiland convert it to carbon

dioxide (CO2) and water (H2O)

23

Pay-for-Performance

Pay for Performance (PFP) cleanup contracting isanother option available for DEP, the Responsible Party,and the petroleum cleanup industry. Under the PFPconcept, a contractor will agree to remediate thecontaminated site to a predetermined level for a fixedtotal price. Interim payments are authorized under PFPupon achieving specified cleanup milestones based on apercentage of reduction in certain contaminants incertain key monitoring wells. This method is in sharpcontrast to the more traditional “Time and Materials”approach where the contractor bills the customer foractual time and materials expenses for various cleanupactivities with no guarantee that a specific reduction incontamination levels will be achieved in return for theirinvestment. For owners and responsible parties who areregistered in a State cleanup program, such as the“PLRIP” or “PCPP” Programs, PFP can limit yourfinancial liability for costs not covered by the State.

Because of the variability in site specific conditions andthe historic uncertainty in the success rate of anyparticular cleanup strategy, cleanup contractors havebeen reluctant to enter into PFP contracts in significantnumbers. PFP is not mandatory for state funded sitesand may not be appropriate for all sites, especially thosewith very complex hydrogeologic conditions. However,the wealth of experience gained by the petroleumcleanup industry over the past 15 years and the positiveresults of PFP projects in Florida and other states arebuilding momentum for transition to PFP. Mostpetroleum cleanup projects can be completed more

Pay for Performance Time and Materials

Initial bid estimate Usually higher Lower

Cleanup life cycle cost Known Unknown

Time to complete cleanup Targeted and guaranteed. Open-ended. Incentive isIncentive is to complete not necessarily to completeahead of schedule on time or at all

Results of cleanup Guaranteed No guarantee

Response to failure of initial Rapid identification and Less fiscal motivation tocleanup methodology or correction of problem. recognize and respond tosystem Additional cost borne by problem. Additional costs

contractor passed on to customer

Fiscal risk associated with Assumed by the cleanup Assumed by the customercleaning up the site contractor

quickly and more cost effectively under PFP. There is astrong financial incentive for the cleanup contractor todo everything possible to achieve the milestones aheadof schedule. In addition, DEP oversight is limited anddirected primarily toward verification of the end points.This procedure allows more flexibility for the contractorto actively manage the cleanup with minimaladministrative paperwork and regulatory delays. Thetable below provides a brief comparison of the PFP andTime and Material approaches to cleanup.

In an effort to promote PFP, the DEP has created a moreflexible option that allows negotiation of cleanup costsfor end points in two separate tiers. The first tier endpoint is an elevated cleanup target level within defaultnatural attenuation concentrations that significantlyreduces the risk to human health and the environmentas well as the financial risk for the cleanup contractor. Ifthe contractor is not comfortable with the certainty ofprogress at this point, they have the option to stop afterthe first tier without penalty. The second tier end pointis to complete site rehabilitation to cleanup target levelsand can be pursued with a greater degree of certainty(and less risk) based on the site-specific experiencegained during tier one.

Regardless of whether or not funding is provided by theDEP, every owner/responsible party should keep thebenefits of PFP in mind and ask their contractor toconsider a PFP contract for their cleanup project.

24

No Further Action/No Further Action with ConditionsNo Further Action

Rule 62-770.680 (1), F.A.C.The final goal of assessment and remediation at acontaminated site is to achieve No Further Action (NFA)status. NFA status means that further assessment orclean up is not required, unless contaminants increaseabove applicable standards or a subsequent dischargeoccurs.No Further Action applies for sites where all of thefollowing apply:

• Free product does not exist• Any contaminated soil in the unsaturated zone

does not exceed background concentrations, or

No Further Action with ConditionsRule 62-770.680 (2), F.A.C.

If certain controls are utilized to eliminate or minimizethe exposure of contaminants to receptors, a site may begranted No Further Action even though contaminationremains in soil and/or groundwater above applicablestandards. There are two types of controls which areused to achieve No Further Action with Conditions(NFAC): engineered controls (not mandatory) andinstitutional controls (mandatory).

Institutional controls are legal documents which arelinked to the property, are part of the title to theproperty (unless the DEP approves removal of thecontrols), and are kept on file with the DEP and notdestroyed. This documentation specifically prohibitsland uses and other activities which may pose anunacceptable threat of exposure to contaminants. Theyare also used to ensure the integrity of engineeringcontrols. Examples of institutional controls arerestrictive covenants (deed restrictions) andconservation easements.

Engineering controls such as pavement, barriers, andslurry walls are designed to limit access and exposure tocontamination or are designed to eliminate furthermigration of the contamination. Engineering controlsmust always be used in conjunction with institutionalcontrols to ensure that the engineering controls areproperly monitored and maintained and that the DEPhas access to inspect the controls.

Ending site cleanup under No Further Action withConditions provisions as an alternative to a completecleanup may result in significant cleanup cost savings.Owners of non-eligible sites (or eligible sites that havecost share requirements or funding caps that will likelybe reached) should give thorough consideration to thisalternative to cleanup completion, as it couldconsiderably reduce their cleanup cost.

In most cases it is necessary for the contamination to beconfined to the property that was the source ofcontamination to qualify for an NFA with Conditionssite closure, since the source property owner cannotimpose institutional controls on neighboring propertyowners. Therefore, an alternative to be considered forsites that have contamination extending beyond theproperty boundaries is to perform a partial cleanup.Once contamination is confined to the source area(within site boundaries), the site may be eligible forNFA with Conditions. This approach could also result inconsiderable cost savings compared to a completecleanup of the source site to the cleanup target levels forsoil and groundwater.

Site owners should be aware that deed restrictions,while not necessarily permanent, may not be removedwithout the DEP’s consent. Natural attenuationprocesses (see page 22) will continue at the site after aNo Further Action with Conditions is issued by theDEP. Supplemental assessment may be performed in thefuture to demonstrate that no residual contaminationremains, and, if this is the case, the DEP may remove therequirement for deed restrictions. Site owners shouldalso be aware that sites that are eligible for fundingassistance from the Inland Protection Trust Fund do notlose eligibility if they agree to complete the cleanupwith No Further Action with Conditions. The residualcontamination remains eligible for future considerationfor funding assistance for supplemental assessment orcleanup.

The DEP has created a registry of sites that havereceived an NFA with Conditions and have engineeringand/or institutional controls in place. To view theregistry or to find out more information regardinginstitutional controls, see DEP’s Contaminated SoilsForum Webpage at: www.dep.state.fl.us/waste/catagories/csf/default.

the lower of applicable direct exposure andleachability standards (See Standards, page 11), oralternate cleanup target levels established throughrisk assessment (See Risk Assessment, page 25).Note: If only leachability standards are exceeded,soils may be tested to determine if they actuallyare leaching contaminants to groundwater.

• Contaminants in ground and surface water do notexceed background concentrations or applicablestandards (See Standards page 11).

25

Risk AssessmentRule 62-770.650, F.A.C.

If a responsible party wishes to use cleanup goalsdifferent from the Groundwater and Soil Cleanup TargetLevels established in Rule 62-777, F.A.C. (See Standards,page 11), then a risk assessment may be performed tojustify those alternate cleanup goals. It is important tonote that Rule 62-770 requires that a proposal to conducta risk assessment be made to the DEP as one of therecommendations of the site assessment report, and theDEP must concur with that recommendation before arisk assessment is initiated. In some cases deedrestrictions will be necessary to ensure the riskassessment exposure assumptions will remain constant.Because a risk assessment can be time consuming andcostly, in most cases it is more appropriate andexpeditious to utilize the No Further Action withConditions provisions of Rule 62-770 (see page 24)rather than to conduct a risk assessment. A riskassessment will take into account actual site-specificexposure parameters and/or toxicity data in order toestimate the risk posed to human health or theenvironment by the contamination.

A site-specific exposure assessment includes:• contaminant concentrations in soil, groundwater,

surface water, and air,• background concentrations of chemicals in

uncontaminated areas,• detailed analysis of soil properties,• actual and potential exposure pathways and

routes,

• actual and potential human and environmentalreceptors for all exposure pathways,

• actual or potential exposure factors such asduration and frequency, and

• established health-based values for allcontaminants.

A toxicity assessment examines the health andenvironmental impacts associated with exposure to:

• potable water, including ingestion, contact withskin, and inhalation of vapors and mists,

• non-potable water, which includes irrigation waterand the crops to which it is applied,

• soil, including inhalation of dusts andconsumption of crops grown in contaminated soil,

• surface water, which includes exposure throughrecreational use, the consumption of fish, andeffects on freshwater or marine life and the foodchain.

A risk characterization may combine all of theseelements to calculate alternative cleanup goals. Thesealternative cleanup goals must consider all availablescientific data, be protective of non-carcinogenic effects,and correspond to a cumulative lifetime risk of oneexcess cancer incidence in a million or less.

Institutional controls (deed restrictions) are oftennecessary to ensure the site-specific exposureassumptions presented in the risk assessment willremain in perpetuity.

26

Time LineTime LineTime LineTime LineTime LineThe amount of time it may take to assess and clean up asite which has been contaminated by a petroleumdischarge may take from several months to well overten years, based upon the severity of the extent andmagnitude of contamination, as well as the strategiesutilized for cleanup. The average cost for assessmentand cleanup is typically $300,000, but some sites cancost millions of dollars to cleanup.

The timeline presented below may be representative of

a worst-case assessment and cleanup scenario – a sitewith soils and groundwater which are impacted bylarge amounts of petroleum contamination. Also, thetimeline does not take into effect additional preparationor review time which is required in the event that anincomplete report is submitted by the cleanupcontractor. Incomplete or improper assessment,cleanup, or reporting will further delay the cleanupschedule and may also make the Responsible Partysubject to enforcement action.

Remedial Action PlanTo be submitted within 90 days of approval of a

Site Assessment Report.

Regulatory Review ofSite Assessment Report

30 days

Site AssessmentTo be initiated within 30 days of discovery.Report due within 270 days of discovery of

contamination.

Contamination Reporting: IMMEDIATE

Beginning of Timeline: Discovery of Discharge

Source RemovalTo be initiated within three days of discovery;

Report to be submitted within 60 days ofcompletion of soil removal.

▼

▼

▼

▼

▼ ▼ ▼ ▼ ▼

▼

27

▼

▼

▼

▼

▼

▼Regulatory Review ofRemedial Action Plan

60 days

Construction and Initiation of ActiveRemediation System or Strategy

Within 120 days of approval ofRemedial Action Plan.

Active RemediationSite specific; typically 1 to 5 years.

Regulatory Review ofMonitoring Only Plan

60 days

Monitored Natural AttenuationBeginning at end of Active Remediation Period

and extending for a period of up to 5 years.

Regulatory Review ofNo Further Action Proposal

60 days

▼ ▼ ▼ ▼ ▼

End of Timeline:CLEANUP COMPLETE

28

The Cleanup ProcessKey Points

✔ Follow notification requirements when a petroleum releaseoccurs so that proper authorities can perform or overseeemergency response.

✔ The proper initial characterization and removal ofcontaminant source material (free product and soils) as soonas possible after a discharge may greatly reduce the amountof time and cost required for complete cleanup.

✔ Direct-push sampling techniques coupled with an on-sitemobile laboratory may be a cost-effective site assessmentstrategy for sites with large contaminant plumes.

✔ A thorough and complete site assessment must be performedin order to determine the most cost-effective and technicallypracticable remediation strategy to address contamination.

✔ Follow the Petroleum Contamination Site Cleanup Criteriaof Chapter 62-770, Florida Administrative Code, andadditional local requirements in order to achieve successfulcleanup, reduce liability, and preserve the value of yourproperty.

✔ And, most importantly:

An ounce of Prevention is worth a pound of Cure!

Follow storage tank registration and maintenancerequirements as well as operational Best

Management Practices in order to avoid a dischargeof petroleum product to the environment! Formore information, see Your Storage Tank Facility

Inspection Guide, available from the DEP atwww.dep.state.fl.us/waste/categories/pcp/default.htm.

YYYYYOUR PETROLEUM STORAGE

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INSPECTION GUIDE

INSPECTION GUIDE

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INSPECTION GUIDE

INSPECTION GUIDE

HOW WELL DO Y

HOW WELL DO Y

HOW WELL DO Y

HOW WELL DO Y

HOW WELL DO YOU KNOW Y

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PETROLEUM STORAGE AND





DISTRIBUTION SYSTEM?





This publication can be made available in large print, tape cassette or braille by request.

This public document was promulgated at a cost of $00.00, or $0.000 per copy,to inform the public about Florida’s Petroleum Cleanup Program.

©2002 by the Florida Department of Environmental Protection

Department of Planning and Environmental ProtectionPollution Prevention Division

218 S. W. First AvenueFort Lauderdale, FL 33301

Phone 954-519-1260 • Fax 954-765-4804

Florida Department of Environmental Protection (DEP)Division of Waste Management

Bureau of Petroleum Storage Systems2600 Blair Road

Tallahassee, FL 32399Phone 850-921-5953 • Fax 850-414-7797

Documents

Petroleum Cleanup Program