Guide to Floridas Petroleum Cleanup Program

Protecting Your Environment

Introduction
This handbook is the result of a state and local government partnership between Floridas Department of Environmental Protection (DEP), Division of Waste Management, Bureau of Petroleum Storage Systems (www.dep.state.fl.us/waste/catagories/pss/default.htm) and Broward Countys Department of Planning and Environmental Protection (DPEP) (www.broward.org/dpep). The intent of the handbook is to provide a clear and concise presentation of the principals of petroleum contamination cleanup and the regulatory requirements found in Chapter 62-770, Florida Administrative Code. If you have questions or comments on this handbook, feel free to e-mail either DEP (Charles.Williams@dep.state.fl.us) or DPEP (jhalsey@broward.org).

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

Table of Contents
Why Florida has a Petroleum Cleanup Program ............................................................................................ 1 History of Floridas Cleanup Program ............................................................................................................. 2 Petroleum Cleanup Program Statistics ............................................................................................................. 3 Chemical Composition of Petroleum Products ............................................................................................... 4 Sources of Petroleum Product Contamination and Their Impacts on the Environment .......................... 5 The Cleanup Process ........................................................................................................................................... 7 Proper Response to a Discharge ........................................................................................................................ 8 Discharge Report Form ....................................................................................................................................... 8 Source Removal ................................................................................................................................................. 10 Standards ............................................................................................................................................................ 11 Site Assessment .................................................................................................................................................. 12 Active Remediation: Introduction .................................................................................................................................................... 14 Air Stripping ................................................................................................................................................... 15 Soil Vapor Extraction ..................................................................................................................................... 16 Air Sparging ................................................................................................................................................... 17 Dual-Phase Extraction ................................................................................................................................... 18 Bioremediation ............................................................................................................................................... 19 Excavation and Treatment or Disposal ....................................................................................................... 20 Chemical Treatment....................................................................................................................................... 21 Monitored Natural Attenuation ...................................................................................................................... 22 Post Active Remediation Monitoring ............................................................................................................. 22 Pay-for-Performance ......................................................................................................................................... 23 No Further Action/No Further Action with Conditions ............................................................................. 24 Risk Assessment ................................................................................................................................................. 25 Time Line ............................................................................................................................................................ 26 Key Points ........................................................................................................................................................... 28

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

Why Florida has a Petroleum Cleanup Program

Ninety percent of Floridas drinking water comes from several aquifers underlying the State, providing over 4.3 billion gallons per day (Figure 1). In addition, the groundwater depth can fluctuate between wet and dry seasons, and in coastal areas may fluctuate daily in response to tidal influences. Florida has a diverse geology ranging from coastal sands, karst limestone, red clay marl, coral rock, organic peat, and silts (Figure 3). Each of these soil types has different size soil particles and other physical and chemical properties and, as a result, will adsorb or trap contaminants to varying degrees.

Figure 1 - Principal Aquifers of Use

The purpose of the petroleum cleanup program is to protect this critical environmental and economic resource from past and future petroleum releases. These releases occur for a variety of reasons including accidental spills, storage tank system leaks, and poor maintenance practices. Groundwater, and any petroleum contamination in or floating on it, is not static. It moves horizontally through the subsurface in several directions, in most cases at a much slower rate than surface water. It also moves vertically with the continuous downward percolation of rainwater. In some places, aquifers overlie other aquifers and there can be vertical flow between them (Figure 2).
Figure 3 - Environmental Geology

This combination of diverse geology, diverse hydrology, and variable physical and chemical dynamics between contaminants and environmental media makes the identification and cleanup of petroleum contamination a challenging task. But, it is a necessary task if Florida is to protect this precious resource for current and future generations.

Figure 2 - Groundwater Flow

History of Floridas Cleanup Program

The Petroleum Cleanup Program
The State of Florida and the Florida Department of Environmental Protection (DEP) have been dealing with the problem of petroleum contamination since 1984. Since that time numerous statutes, administrative rules, and guidance documents have established requirements and 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 for

newly reported discharges. The responsible party or parties and/or their insurance providers must bear the cost for any required assessment and cleanup. Chapter 376, Florida Statutes (1984)
q Instituted compliance and prevention measures for petroleum storage systems q Chapter 62-761, F.A.C., Stationary Tank Rule (New, May 1984) q Contaminated sites were discovered as new leak prevention measures were implemented w

Inland Protection Trust Fund (1986)

q Part of the State Underground Petroleum Environmental Response (SUPER) Act q Authorized the DEP to establish criteria for the prioritization, assessment and cleanup, and reimbursement for cleanup of petroleum contaminated sites. q Established funding source for assessment and cleanup of petroleum contaminated sites, derived from a tax on w w petroleum products produced in or imported into Florida q Funding assistance available in two formats: 1) State Cleanup conducted in priority order by a State lead contractor, or 2) Reimbursement on a first come, first served basis for work completed in accordance with FDEP rules

Early Detection Incentive Program (EDI) (1986)

q First State assisted cleanup program q 100% State funding for cleanup if property owners report releases q Application period ended at the end of 1988

Petroleum Liability & Restoration Insurance Program (PLRIP) (1989)

q Intended for active facilities q State underwrote the restoration portion of insurance coverage for new discharges, subject to various caps and deductibles depending on discharge date q State restoration coverage ended on December 31, 1998

Abandoned Tank Restoration Program (ATRP) (1990)

q Created to address contamination at facilities that were out of business as of March 1990 q Application period ended in June 1996; however, the ATRP application window is open indefinitely for property owners who are unable to pay for the closure of abandoned tanks q 100% State funding (less deductible)

Preapproval Program (1996)

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

Petroleum Cleanup Participation Program (PCPP) (1996)

q Created to include sites that had missed all previous opportunities for State assistance q Only for discharges reported prior to 1995 q Application deadline was the end of 1998 q The responsible party must pay a percentage of cleanup costs and prepare a limited scope assessment at their own expense q Has cap on amount of coverage

Preapproved Advanced Cleanup (PAC) (1996)

q For sites already eligible in a State cleanup program other than PCPP q Provides funding assistance out of priority order q The responsible party must pay a percentage of cleanup costs and prepare a limited scope assessment at their own expense q Has cap on amount of coverage

Free Product Recovery Initiative (1999)

q For sites already eligible in a State cleanup program q Provides funding for the preapproved removal of free-phase petroleum product out of priority order.

Site Rehabilitation Agreements (1999)

q 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. q 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.

Petroleum Cleanup Program Statistics

Implementation of Floridas Petroleum Cleanup Program is the responsibility of DEPs Bureau of Petroleum Storage Systems located in Tallahassee. The Bureau contracts 15 contracted local county or Department of Health environmental programs covering 23 counties throughout the state to assist in the management and oversight of individual cleanups.

Contracted Local Programs

de

ne ro

tract with Escam con bia

Okaloosa Walton

C
nty ou

Un

Escambia

Alachua Duval Santa Rosa

Bay Volusia Seminole, including Lake

Program Statistics*
52,196 Active Registered Petroleum Storage Tanks at 20,097 Facilities

Polk, including Hardee, Highlands, and Osceola Pinellas

Orange Brevard

22,318 Sites with Confirmed Petroleum Contamination

Hillsborough Sarasota Palm Beach Broward Collier Miami-Dade

4%
61%

17% 79%
39%

Underground Tanks Above-Ground Tanks

Eligible for State Funding Assistance Ineligible for State Funding Assistance Both Eligible and Ineligible Discharges

14,927 Eligible Sites (Awaiting Cleanup or in Progress)

22,318 Sites with Confirmed Petroleum Contamination

Distribution of Eligible Discharge Priority Scores*

5000
4,613
3,174

54%

Number of Discharges

46%

4000
3000
2000
1000
0

29%
46%

25%

1,543 1,893

1,558

1,204
786

1,431 476

Sites Awaiting Cleanup Sites with Cleanup Underway

Cleanup Complete Cleanup Underway Awaiting Cleanup

219

107

0-9

10-19

20-29

30-39

40-49

50-59

60-69

70-79

80-89

90-99

>100

Scoring Range of Petroleum Discharges

*Note: December 2001 Data

Floridas storage tank registration program and the requirement to report discharges helps identify contaminated sites. After prioritizing sites by assigning scores based upon health threats, cleanup began with the highest risk sites and is proceeding toward those sites that pose a lessor risk to human health and the environment.

*Note: February 2002 Data

The priority score for a petroleum site establishes a sites place in line for cleanup with State funds or priority for enforcement action. The priority score represents the relative threat the site poses to potential receptors. The higher the score, the greater the potential threat.

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

Chemical Composition of Petroleum Products

Defraction Column Lighter Products

Common Petroleum-based Products

q q q q

Gasoline Diesel Fuel Aviation Fuel (Kerosene) Oils and Lubricants

Furnace Petroleum Crude Oil Heavier Products

Product Specific Refinement Process

w
v When petroleum products, or the waste associated with use of these products, are released into the environment, they chemically and biologically interact with the soil, groundwater, and microorganisms. v The ratios of these chemicals serve as a fingerprint for the type of product (diesel, gasoline, etc.) originally released into the environment.

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

Chemical

Symbol

Human Toxicity
Probable carcinogen (cancer-causing agent), Central Nervous System (CNS) depression, Irregular heart rhythm Abdominal pain, vomiting; CNS effects; Heart and liver damage; Bone marrow damage Mutagenic (causes mutations), CNS depression, Respiratory irritation, Liver, kidney damage Narcosis, CNS effects, Skin and eye irritation Abdominal Pain, Jaundice, Renal failure, Optical neuritis and corneal damage General Class with varying degrees of toxicity, several of which are potential carcinogens. 17 specific PAHs are regulated under Floridas Petroleum Cleanup Program Varying degrees of toxicity. Arsenic is a carcinogen and has reproductive 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. Its use began as a replacement for lead in gasoline because of health hazards associated with lead. MTBE has distinctive physical properties that result in it being highly soluble, persistent in the environment, and able to migrate through the ground. DEP has required the monitoring and cleanup of MTBE at petroleum contaminated sites since February, 1990, and continues to monitor studies focusing on the potential health effects of MTBE and other fuel additives. For more information, visit DEPs Petroleum Cleanup Program web site at: www.dep.state.fl.us/waste/catagories/pcp. 4

Sources of Petroleum Product Contamination and Their Impacts on the Environment

Common Sources The most common sources of petroleum contamination from 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 and petroleum products can contaminate: Soil Groundwater Surface water Air Contaminant Plumes The type, amount, and duration of the discharge, the length of time elapsed since the discharge, and the hydrogeologic conditions underlying the site, will determine the size, length, and depth of the contaminant plume. Many factors will determine how quickly 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 dissolved contamination is usually concentrated near the top of the groundwater table. As the water table rises and falls with seasonal variations and drought or flood conditions, contaminants concentrate in smear zones above and below the mean water table. Adequately treating these smear zones plays a key role in the remediation process.

GROUND SURFACE

Expanded View of Free Product Trapped in Pores Between Soil and Sediment Particles
Vapor Solid Water

Petroleum Storage Tank

Volatilization
Free Product Petroleum Hydrocarbon Leak

Sorbed Contaminants

Free Product

Dissolved Hydrocarbons

Biodegradation
WATER TABLE

Free Product

Dispersion and Dilution

AQUIFER Smear Zone Dissolved Hydrocarbon Plume

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

Threats from Contaminants in the Environment Though relatively rare, explosive vapors from discharged petroleum products can accumulate in confined spaces such as an abandoned tank, a subsurface cable vault, in sewer pipes or beneath buildings. Ignition of these vapors can cause an explosion with potentially catastrophic results. Human exposure to petroleum contaminants can occur through: Ingestion of contaminated drinking water and soil residues, Inhalation of vapors and airborne soils, Contact of contaminants with skin (dermal exposure). Health impacts of exposure to petroleum contamination may include skin and lung irritation, headaches, dizziness, fatigue, diarrhea, cramps, and nervous system effects. Benzene and other chemicals found in petroleum products have been determined to be carcinogenic (cause cancer). Chronic (long-term) exposure to contaminants by ingestion and inhalation was considered in the derivation of the petroleum cleanup target levels referenced in Chapter 62-777, Florida Administrative Code (F. A. C.) discussed further on page 11. More information regarding toxicity of petroleum chemicals is available from the Agency for Toxic Substances and Diseases Registry, an agency of the U.S. Department of Health and Human Services. Their homepage address on the world wide web is www.atsdr.cdc.gov. Petroleum contamination may also cause adverse impacts to nearby plants and animals, from the smallest to the largest members of the natural food chain. Plants growing in contaminated soils or water may die or appear distressed. Animals may drink contaminated water or feed upon plants or other animals which have been exposed to contaminants. Although not visible to the naked eye, subsurface elements of ecosystems, such as microorganisms, may be overwhelmed by contaminants. Sensitive habitats, such as wetlands and marine ecosystems, are particularly susceptible to petroleum chemicals.

HUMAN EXPOSURE TO CONTAMINATED SOIL AND GROUNDWATER

DEAD OR DYING TREES AND PLANTS

LEAKING GASOLINE HAZARDOUS VAPORS IN SOIL LEAKING TANK

LEAKING BARRELS

WATER TABLE CONTAMINATED DRINKING WATER WELL

WATER TABLE

PICTURE OF EXCAVATION WITH GROUNDWATER CONTAMINATED

The Cleanup Process

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

Discovery of Discharge

w
w

Reporting
Rule 62-770.250, F.A.C.

Source Removal
Rule 62-770.300, F.A.C.

w
w

Site Assessment
Rule 62-770.600, F.A.C.

w Active Remediation
Rule 62-770.700, F.A.C.

w Risk Assessment
Rule 62-770.650, F.A.C.

w Monitored Natural Attenuation

Rule 62-770.690, F.A.C.

w w

w Post Active Remediation Monitoring

Rule 62-770.750, F.A.C.

w No Further Action (NFA)

or

No Further Action With Conditions (NFAC)

Rule 62-770.680, F.A.C.

w w w

Proper Response to a Discharge

Rule 62-770.250, F.A.C.

Reporting
A discharge of petroleum (or petroleum product) may occur or be discovered in a variety of ways. Reporting to the DEP or a contracted local program is required for the following: Analytical or field tests of surface water, groundwater, or soils which exceed applicable standards, or A spill or overfill event of a quantity greater than 25 gallons, or A spill or overfill event of less than 25 gallons on a previous surface unless immediately excavated, or Visual observation of free product or sheen in surface water, groundwater, soils, basements, sewers, and utility lines at the facility or in the surrounding area, or Visual observation of contamination during such activities as compliance inspections and tank closure or upgrade activities, or Detection of free product in monitoring wells. Upon discovery that petroleum product has been released into the environment, notification must be

provided by the discharger using a Discharge Report Form (DRF). If the discharger is unknown, or if a unreported past discharge is discovered, the DRF should be submitted by the facility owner or operator. A DRF does not have to be submitted for a previouslyknown and reported discharge. If the discharge was from a regulated storage tank system, the DRF must be delivered or faxed to the County tank compliance program or the DEP District office within 24 hours of discovery, or before the close of the next business day. For all other discharges of petroleum or petroleum product, the discharge must be reported within one week of discovery.

Additional Notification
Oil spills to navigable waters must be reported within one hour to the National Response Center or the Florida Marine Patrol. Spills that are not to navigable waters, but pose an immediate threat to human health or the environment, must be immediately reported to the State Warning Point or the Local Fire Department. National Response Center: 1-800-424-8802 State Warning Point: 1-800-320-0519 Florida Marine Patrol: 1-800-342-5367

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DISPENSERS CONCRETE FOUNDATION

UNDERGROUND PIPING

UNDERGROUND FUEL STORAGE TANKS

LEAKING FUEL

Source Removal
Rule 62-770.300, F.A.C.

Free Product Recovery and Disposal

When released in the subsurface, petroleum may form free floating product on top of the water table and can act as a continuing source of contamination. If free floating petroleum product (in excess of 0.01 foot thickness) is discovered at a site, the responsible party must take steps to obtain cleanup services for product recovery or initiate product recovery within three days. These requirements only apply to discharges which are not eligible for financial assistance through the DEP Petroleum Cleanup Program. For Program-eligible discharges, free product does not have to be removed prior to the time that assessment and remediation activities are performed in priority order. However, State funding assistance may be sought for free product recovery out of priority order through the Free Product Recovery Initiative (See page 2). Free product may be recovered without prior regulatory approval 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 specific requirements are met. Other recovery methods must be evaluated, proposed, and submitted to DEP or the contracted local program for approval prior to implementation. Within 10 days after initiation of product recovery, written notification must be provided to DEP or the contracted local program for review. Free product recovery should continue until as much free product has been removed as practicable.
Bailer containing petroleum free product

Soil Removal, Treatment, and Disposal

If contaminated soil exists at a site, excavation of contaminated soil for proper treatment or proper disposal may be performed. The DEP encourages the treatment of contaminated soils over disposal. The excavation, treatment or disposal of contaminated soil may be performed prior to regulatory approval under specific conditions, including: Contamination is not spread into previously uncontaminated areas, Flammable products are handled in a safe manner, Excavated and stockpiled soils are secured in a manner that prevents exposure of contaminated soil to receptors and precipitation, The excavation pit is secured to prevent accidental or intentional entry by the public, Excavated soil is not to be stored or stockpiled on site beyond certain time limits. Contaminated soil is treated or disposed of in accordance with applicable DEP and local rules and regulations.

Source Removal Report

Within 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 be submitted to the DEP or the contracted local program for review.

Tank and contaminated soil removal

10

Standards
To determine the degree and extent of contamination, the analytical results of soil, groundwater, and surface 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 determine appropriate cleanup goals at contaminated sites. The standards represent the maximum allowable concentration of contaminant allowable in the environment and are based on toxicity evaluation of both carcinogenic (cancer-related) and non-carcinogenic effects, as well as considerations of taste and odor. Groundwater criteria are based 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 ug/L means parts per billion (ppb)

The maximum amount of contaminant allowable in soil subjected to residential uses (Note: These levels must be met unless the property deed is restricted to prohibit residential use.)

mg/kg means parts per million (ppm)

That amount of contaminant present in the soil that would leach into water and result in water contamination equal to those concentrations 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

11

Site Assessment
Rule 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 of contamination in soil, groundwater, and surface water, and Assess the potential threats of contamination to human and ecological receptors. Many tools may be used by trained and certified personnel to accomplish the site assessment. A. Monitoring Wells x Installed using specific and required construction techniques. x Used to define the vertical and horizontal extent of a groundwater contaminant plume. x Used as permanent points for groundwater sampling and analysis. x Also used to monitor groundwater table depth and direction of groundwater flow. B. Water Level Indicator x Used to determine the depth to site groundwater inside a monitoring well. C. Direct Push Rig x Push or hammer tools, sensors, and sampling devices into the subsurface. x Used to quickly obtain continuous soil cores or soil and groundwater samples to determine lithologies and petroleum content. x Used to install pre-packed microwells or to determine the most appropriate monitoring well locations and depths. x Usually used with a FID or field GC/MS D. Hand Auger x Tool used to collect surface and shallow subsurface soil samples.

A
MONITORING WELL CONSTRUCTION

LIGHT INDICATOR

aaaaa aaaaa

MONITORING WELL COVER MONITORING WELL CONTAINMENT

REEL

CONCRETE/GRADE

B D C

LOCKING CAP VENT HOLE 1/4-8/8 4 DIA. SCH 40 PVC PIPE BENTONITE SEAL

CASING

5 FEET BELOW WATER TABLE

FACTORY SLOTTED (0.0.20 SLOTS)

BUT NOT MORE THAN 40

ELECTRIC CABLE

WATER LEVEL SAND PACK OR PEA GRAVEL 8 DIA. BORED HOLE

WATER LEVEL
5 FEET BELOW WATER TABLE

ELECTRODE WATER

CAP

LOCATION OF FORMER LEAKING TANK

CONTAMINATION ADSORBED ONTO SOIL

WATER TABLE

GROUNDWATER CONTAMINATED WITH DISSOLVED HYDROCARBON

FLOATING HYDROCARBON LAYER

DIRECTION OF GROUNDWATER FLOW

12

Site Assessment, (continued)

E. Drill Rig x The most common types use a hollow stem rotating auger or a rotary drill bit to penetrate the subsurface. x Used to collect information on subsurface lithologies and petroleum content. x Used in the installation of permanent groundwater monitoring and recovery wells. x Usually used with a FID or field GC. F. Flame Ionization Detector (FID) x Hand-held instrument which provides a quick assessment of hydrocarbon content in samples x Type of Organic Vapor Analyzer (OVA) which detects compounds by burning them in a hydrogen flame. x Used to cost-effectively screen a site for soil and groundwater contamination to determine which samples should be collected and then analyzed in the laboratory . G. Gas Chromatograph (GC) x Used to detect and quantify contaminants in samples while in the field. x Should be correlated and corroborated with fixedlaboratory results. H. Peristaltic Pump x May be used to collect groundwater samples from dedicated monitoring wells.

LOCATION OF FORMER LEAKING TANK CONTAMINATION ADSORBED ONTO SOIL FLOATING HYDROCARBON LAYER

GROUNDWATER CONTAMINATED WITH DISSOLVED HYDROCARBON DIRECTION OF GROUNDWATER FLOW

WATER TABLE

13

Active Remediation
Rule 62-770.700, F.A.C. Introduction
Once the full extent of contamination has been determined through a complete site assessment, several options may 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: x x x x 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 surface water 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 cleanup petroleum contamination. Some remediation technologies are designed to clean up contamination in either soil or groundwater; others are designed to address both. Prior to construction and/or implementation, a Remedial Action Plan (RAP) must be approved by DEP or the Contracted Local Program. The RAP must be certified by a Florida Professional Engineer and must propose and justify the use of a particular remediation strategy. Pilot tests (short-term field studies) may be conducted to develop the remediation strategy or design proposed in the RAP. Design overviews of the following remediation technologies are featured in this brochure:

Air Stripping Air Sparging/Soil Vapor Extraction

Bioremediation

Excavation and Treatment or Disposal Chemical Treatment

Although widely used, the technologies featured in this brochure are only a few of the remediation strategies which are currently available to cleanup contaminated sites. The cost associated with these technologies varies widely, and the applicability and effectiveness of any remediation technology is dependent upon many sitespecific characteristics. By discussing these technologies, DEP does not express or imply that these technologies are preferred over others which may be available or that one of these technologies is the most effective or appropriate strategy for cleaning up a particular contaminated site. 14

Active Remediation
Air Stripping (Pump and Treat)

MIST ELIMINATOR

SPRAY DISTRIBUTION NOZZLE EQUIPMENT COMPOUND

POLYPROPYLENE PACKING

Low-profile Tray Stripper

CONTROL PANEL

CONCRETE BASE

VALVES

OBSERVATION/ CLEAN OUT PORT INFLUENT SAMPLE PORT CHECK VALVE AIR STRIPPER ASSEMBLY COARSE ROCK FILL CONTAMINATED GROUNDWATER PRESSURE GAUGE BLOWER MOTOR CARBON CANISTERS

INFILTRATION GALLERY FILTER CLOTH CLEAN OUT PIPE

PERFORATED METAL PIPING

RECOVERY WELL WITH PUMP

Air Stripping
Air stripping is a treatment process whereby contaminated groundwater is pumped from the subsurface and then exposed to a flow of air. By greatly increasing the surface area of contaminated water exposed to air, dissolved volatile chemicals are removed 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 to distribute contaminated water over packing in the column, a fan to force air countercurrent to the water flow, and a sump at the bottom of the tower to collect treated water. Contaminants in the air stream are either discharged into the atmosphere or captured. Discharged vapors must meet Federal EPA air discharge standards or they must be treated. Treated water is either returned to the groundwater via an infiltration gallery or discharged to sanitary sewer, storm water, or surface water bodies. As a final step prior to recharge or discharge, the water is often pumped through a series of canisters or columns containing granular activated carbon (GAC), a material which adsorbs 15 residual dissolved organic contaminants. Other types of aeration equipment include the diffused aerator, spray aerator and tray stripper. The low-profile tray stripper (shown above left) is a unit consisting of a number of trays packed into a very small chamber to maximize air-water contact while minimizing space. Typical air stripping equipment includes specially designed groundwater recovery wells and pumps, oil/ water separators, blowers, tower or tray strippers, transfer pumps, GAC canisters, equipment controllers, infiltration galleries, piping networks, valves, water flow meters, and manifolds. Auxiliary equipment that can be added to the basic air stripper system includes an air heater to improve removal efficiencies; automated control systems with sump level switches and safety features, such as differential pressure monitors, high sump level switches, and explosion-proof components; and air emission control and treatment systems, such as activated carbon units, catalytic oxidizers, or thermal oxidizers.

Active Remediation
Soil Vapor Extraction
VENT TO ATMOSPHERE CONCRETE FOUNDATION CARBON CANISTER

VALVE

HORIZONTAL VAPOR EXTRACTION WELL

BLOWER MOTOR

GAUGE

CONTAMINATED SOIL

CONCRETE FOUNDATION DRAIN VALVE

VERTICAL VAPOR EXTRACTION WELL

HORIZONTAL VAPOR EXTRACTION WELL

Thermal/Catalytic Oxidation Unit

Soil Vapor Extraction Soil vapor extraction (SVE) is the process of applying a vacuum to soils located above the water table (the vadose zone) causing a controlled flow of air to volatilize and remove contaminants trapped in the soil or product floating on top of the water table. The vacuum is applied through vertical or horizontal extraction wells. Volatile contaminants exiting the soil in the gas stream are usually recovered using granular activated carbon (GAC) adsorption canisters (as shown above) and/or treated using a thermal oxidizer, a catalytic oxidizer, or a combustion engine. Typical equipment includes specially designed vapor extraction wells, water condensation tanks, transfer pumps, blowers, thermal oxidation or vapor combustion units, equipment controllers, GAC canisters, piping networks, valves, vacuum gauges, air flow meters, and manifolds. The effectiveness of SVE may be improved by injecting air into vadose zone soils or by covering the overlying soil surface with a geomembrane. Groundwater depression pumps may also be used to reduce groundwater upwelling induced by the vacuum or to increase the depth of the vadose zone.

Off-gas Treatment: Vapor-phase Carbon Adsorption System Vapor-phase carbon adsorption is a remediation technology in which pollutants are removed from extracted vapors by physical adsorption onto activated carbon grains. Carbon is activated for this purpose by processing the carbon to create porous particles with a large internal surface area that attracts and adsorbs contaminant molecules. Granular-activated carbon (GAC) systems typically consist of one or more vessels filled with activated carbon connected in series and/or parallel. Off-gas Treatment: Thermal/Catalytic Oxidation Oxidation equipment may also be used for destroying contaminants in the exhaust gas from air strippers and SVE systems. Thermal oxidation units destroy contaminants in a high-temperature combustor (see inset above). Catalytic oxidation accelerates the rate of contaminant destruction by adsorbing oxygen and the contaminant onto the catalyst surface where they react, destroying the contaminant. Trace concentrations of chemicals in contaminated air streams are destroyed at lower temperatures in catalytic oxidation units than those used in thermal oxidation. Thermal and catalytic oxidation units are typically single chamber units mounted on a trailer or skids, equipped with a propane or natural gas burner and stack. 16

Active Remediation
Air Sparging

VENT TO ATMOSPHERE

SOIL VAPOR MONITORING

CARBON CANISTER
MONITORING WELL

COMPRESSOR CONCRETE FOUNDATION

BLOWER

SOIL

DRAIN VALVE

VAPOR EXTRACTION WELL

VAPOR EXTRACTION WELL AIR SPARGE WELL

CONTAMINANT VAPOR

CONTAMINATED GROUNDWATER

AIR

Air Sparging (with Soil Vapor Extraction) Air sparging is the process of injecting air through a contaminated aquifer to agitate and volatilize contaminants dissolved in the groundwater or trapped in 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 recover or treat the generated vapor phase contamination (see page 16 for an explanation of SVE and off-gas treatment). Another benefit of air sparging technology is that the oxygen added to contaminated groundwater and vadose zone soils can also enhance aerobic biodegradation of contaminants below and above the groundwater table (see page 19 for an explanation of bioremediation). Typical equipment, in addition to that used for SVE, includes specially designed air sparge wells, blowers, piping networks, valves, pressure gauges, air flow meters, and manifolds.

17

Active Remediation
Dual-Phase Extraction

STACK TO ATMOSPHERE

CARBON VESSELS VAPOR LINE VENT TO ATMOSPHERE

DISCHARGE SILENCER BALL VALVE INLET FILTER w

PARTICULATE FILTER

AIR STRIPPER CONTROL PANEL AIR STRIPPER BASE BLOWER MOTOR

BLEED AIR DILUTION VALVE

LIQUID LINE VACUUM PUMP

CONTAMINANT VAPORS

TRANSFER PUMP DISCHARGE TO INFILTRATION GALLERY

MOISTURE SEPARATOR RECOVERY WELLS CONTAMINATED GROUNDWATER

PORTABLE SKID

CONCRETE FOUNDATION

Dual-Phase Extraction Dual-Phase Extraction (DPE), also known as multiphase extraction, is a technology that uses a high vacuum system to simultaneously remove various combinations of contaminated groundwater, free-phase petroleum product, and hydrocarbon vapor from the subsurface. In DPE systems for liquid/vapor treatment, vacuum extraction wells are screened over the zones of contaminated soils and groundwater and, therefore, remove contaminants from above and below the water table. The vacuum lowers the water table around the extraction wells, making newly exposed vadose zone soils accessible to vapor extraction. Once above ground, the extracted vapors or liquid-phase organics and groundwater are separated and treated (see Off-Gas Treatment, page 16, and Air Stripping, page 15). DPE for liquid/vapor treatment is often combined with bioremediation (see page 19) and/or air sparging (see page 17). Use of dual phase extraction with these technologies can shorten the cleanup time at a site. An oil/water separator is typically used in DPE systems which are applied to sites which have free-phase petroleum product. Typical equipment for DPE also includes specially designed extraction wells, a condensation tank, an air stripper, a vapor treatment unit, Granular Activated Carbon (GAC) canisters, piping, pressure gauges, air flow meters, and valves.

18

Active Remediation
Bioremediation

Aerobic Microorganisms eat oil or other organic contaminants

Microorganisms digest oil and convert it to carbon dioxide (CO2) and water (H2O)

Microorganisms give off CO2 and H2O

Ground Surface Injection Wells

Former UST Source Treatment in Saturated Zone Oxygen Slurry and/or Nutrient Delivered

Source Treatment in Tank Pit

Dissolved Phase Hydrocarbon Plume

Bioremediation Aerobic biodegradation is the natural process of the metabolic breakdown of contaminants by microorganisms into less harmful components. Under optimum physical, chemical, and biological conditions, the natural population of subsurface microorganisms multiplies rapidly and uses petroleum contamination as a food source, leaving the harmless by-products of additional microbial growth, carbon dioxide, and water. However, success often is limited by the lack of sufficient oxygen for microorganisms in the contaminated zones. Bio-remediation is a process that attempts to create such optimum conditions by introducing essential nutrients and air or another oxygen source to the contaminated area in order to enhance the natural population of microorganisms. During hydrogen peroxide enhancement, a dilute solution of hydrogen peroxide is circulated through the contaminated groundwater zone to increase the oxygen 19 content of groundwater and enhance the rate of aerobic biodegradation of organic contaminants by naturally occurring microbes. Air sparging below the water table also increases groundwater oxygen concentration and enhances the rate of biological degradation of organic contaminants by naturally occurring microbes (see page 17 for an explanation of air sparging). Bioremediation may also be accomplished by introducing bacteria which have been specialized to thrive on particular contaminants. Although more expensive, it is possible to create external (above-ground) treatment processes for soil or groundwater that provide a more controlled environment and more predictable results. Typical equipment varies. Most subsurface applications involve introduction points for the oxygen source and nutrients and some form of slurry or solution delivery apparatus involving mixers and pumps.

Active Remediation
Excavation and Treatment or Disposal

Excavation and Treatment or Disposal As an alternative to the previously described technologies which treat soils without removing them, contaminated soils are often excavated and then treated or disposed. Most often excavated soils are treated at a commercial soil thermal treatment facility or disposed in a permitted, lined landfill. Depending on site-specific circumstances, these activities may be conducted as a source removal (see page 10). Other alternatives for treating excavated soils include technologies such as bioremediation and soil washing. DEP prefers treatment methods over disposal methods for contaminated soil. Otherwise referred to as dig and burn, contaminated soil may be excavated and transported to a permitted thermal treatment facility, where it is exposed to high temperature for a sufficient amount of time to volatilize and fully combust the contaminants. The rotary kiln is a slightly-inclined, rotating cylinder that serves as a combustion chamber and operates at temperatures up to 980 C (1,800 F). Often auxiliary fuels are employed to initiate and sustain combustion. Exiting gases require treatment by an integrated air pollution-control system to destroy volatile hydrocarbon vapors, remove particulates, and neutralize and remove acid gases. Typical equipment for soil excavation includes excavators, loaders, and dump trucks. Commercial thermal treatment systems are typically kilns equipped with an afterburner, a quench, and an air pollution control system.

20

Active Remediation
Chemical Treatment

CHEMICAL STORAGE TANK

CONCRETE FOUNDATION

Tank and control equipment stored inside trailer

SOIL LIQUID PUMP SOIL

CONTAMINATED GROUNDWATER

CHEMICAL SLURRY

Injection lines leading from the trailer into the subsurface.

Chemical Treatment Though there are many types of chemical treatments, the chemicals most typically used to destroy petroleum contaminants in soil and groundwater are oxidants. Oxidants chemically breakdown hydrocarbon molecules into harmless ones, like water and carbon dioxide. The most common oxidants authorized for use under certain conditions are hydrogen peroxide, permanganates, and ozone. At some sites, a catalyst is used with the oxidant. A catalyst is a chemical that increases the strength or speed of a process. For instance, if hydrogen peroxide is mixed with an iron catalyst, it produces a strong chemical called a free radical. Free radicals can destroy more harmful chemicals that hydrogen peroxide alone. The following equation demonstrates this particular overall process:

Hydrogen Peroxide (H2O2) and Hydrocarbon Contaminant (CnHx ) in the presence of iron catalyst (Fe2+) makes Water (H20) and Carbon Dioxide (CO2)

H2O2 + CnHx

Fe2+

H20 + CO2

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

21

Monitored Natural Attenuation

Rule 62-770.690, F.A.C.
Natural attenuation refers to natural processes which may contain the spread of contamination and reduce contamination in groundwater and soil to acceptable levels. 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 regular schedule to ensure that the reduction of contamination is proceeding at rates consistent with meeting cleanup objectives. However, the use of monitored natural attenuation has some advantages when compared to other remediation strategies; it generates less remediation wastes, is less intrusive and allows the site to remain in productive use, and, in many cases, it requires less overall cost. The use of exclusive monitored natural attenuation is clearly not appropriate for every contaminated site. Monitored natural attenuation may only be used at sites which meet certain requirements, including: The contamination will not pose an unacceptable risk to human health or the environment, Free product and contaminated soil have been effectively removed from the site. Otherwise, the rate at which contamination continues to leach into groundwater may exceed the rate at which natural processes can attenuate the groundwater contamination, Groundwater contaminant plumes are stable or decreasing in size and are not migrating, Groundwater and Soil Cleanup Target Levels (Rule 62-777, F.A.C.), are expected to be achieved in a reasonable period of time.

Aerobic Microorganisms consume oil or other organic contaminants

Microorganisms digest oil and convert it to carbon dioxide (CO2) and water (H2O)

Microorganisms give off CO2 and H2O

Post Active Remediation Monitoring

Rule 62-770.750, F.A.C.
When groundwater contamination appears to have met the applicable cleanup target levels for No Further Action criteria (see No Further Action, page 24), use of an active remediation system may be discontinued. Following the discontinuation of an active soil or groundwater remediation system, groundwater monitoring must be performed for a minimum of one (1) year (unless contamination was only present in the unsaturated zone). The purpose of post active remediation monitoring is to ensure that contaminant concentrations do not rebound above applicable standards. Even if groundwater 22 standards are met when a system is active, contamination may desorb from subsurface soil particles and continue to contaminate groundwater once the system is inactive. In the event that contaminant concentrations do increase beyond acceptable levels, the remediation system may need to be reactivated. For this reason, it may be necessary for remediation equipment to be maintained and remain operational during post active remediation monitoring. If applicable standards are still met after the required post active remediation monitoring period is complete, a site may be eligible for No Further Action.

Pay-for-Performance
Pay for Performance (PFP) cleanup contracting is another option available for DEP, the Responsible Party, and the petroleum cleanup industry. Under the PFP concept, a contractor will agree to remediate the contaminated site to a predetermined level for a fixed total price. Interim payments are authorized under PFP upon achieving specified cleanup milestones based on a percentage of reduction in certain contaminants in certain key monitoring wells. This method is in sharp contrast to the more traditional Time and Materials approach where the contractor bills the customer for actual time and materials expenses for various cleanup activities with no guarantee that a specific reduction in contamination levels will be achieved in return for their investment. For owners and responsible parties who are registered in a State cleanup program, such as the PLRIP or PCPP Programs, PFP can limit your financial liability for costs not covered by the State. Because of the variability in site specific conditions and the historic uncertainty in the success rate of any particular cleanup strategy, cleanup contractors have been reluctant to enter into PFP contracts in significant numbers. PFP is not mandatory for state funded sites and may not be appropriate for all sites, especially those with very complex hydrogeologic conditions. However, the wealth of experience gained by the petroleum cleanup industry over the past 15 years and the positive results of PFP projects in Florida and other states are building momentum for transition to PFP. Most petroleum cleanup projects can be completed more quickly and more cost effectively under PFP. There is a strong financial incentive for the cleanup contractor to do everything possible to achieve the milestones ahead of schedule. In addition, DEP oversight is limited and directed primarily toward verification of the end points. This procedure allows more flexibility for the contractor to actively manage the cleanup with minimal administrative paperwork and regulatory delays. The table below provides a brief comparison of the PFP and Time and Material approaches to cleanup. In an effort to promote PFP, the DEP has created a more flexible option that allows negotiation of cleanup costs for end points in two separate tiers. The first tier end point is an elevated cleanup target level within default natural attenuation concentrations that significantly reduces the risk to human health and the environment as well as the financial risk for the cleanup contractor. If the contractor is not comfortable with the certainty of progress at this point, they have the option to stop after the first tier without penalty. The second tier end point is to complete site rehabilitation to cleanup target levels and can be pursued with a greater degree of certainty (and less risk) based on the site-specific experience gained during tier one. Regardless of whether or not funding is provided by the DEP, every owner/responsible party should keep the benefits of PFP in mind and ask their contractor to consider a PFP contract for their cleanup project.

Pay for Performance Initial bid estimate Cleanup life cycle cost Time to complete cleanup Usually higher Known Targeted and guaranteed. Incentive is to complete ahead of schedule Guaranteed Rapid identification and correction of problem. Additional cost borne by contractor Assumed by the cleanup contractor

Time and Materials Lower Unknown Open-ended. Incentive is not necessarily to complete on time or at all No guarantee Less fiscal motivation to recognize and respond to problem. Additional costs passed on to customer Assumed by the customer

Results of cleanup Response to failure of initial cleanup methodology or system Fiscal risk associated with cleaning up the site

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No Further Action/No Further Action with Conditions

No Further Action Rule 62-770.680 (1), F.A.C.
The final goal of assessment and remediation at a contaminated site is to achieve No Further Action (NFA) status. NFA status means that further assessment or clean up is not required, unless contaminants increase above applicable standards or a subsequent discharge occurs. No Further Action applies for sites where all of the following apply: Free product does not exist Any contaminated soil in the unsaturated zone does not exceed background concentrations, or the lower of applicable direct exposure and leachability standards (See Standards, page 11), or alternate cleanup target levels established through risk assessment (See Risk Assessment, page 25). Note: If only leachability standards are exceeded, soils may be tested to determine if they actually are leaching contaminants to groundwater. Contaminants in ground and surface water do not exceed background concentrations or applicable standards (See Standards page 11).

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

If certain controls are utilized to eliminate or minimize the exposure of contaminants to receptors, a site may be granted No Further Action even though contamination remains in soil and/or groundwater above applicable standards. There are two types of controls which are used to achieve No Further Action with Conditions (NFAC): engineered controls (not mandatory) and institutional controls (mandatory). Institutional controls are legal documents which are linked to the property, are part of the title to the property (unless the DEP approves removal of the controls), and are kept on file with the DEP and not destroyed. This documentation specifically prohibits land uses and other activities which may pose an unacceptable threat of exposure to contaminants. They are also used to ensure the integrity of engineering controls. Examples of institutional controls are restrictive covenants (deed restrictions) and conservation easements. Engineering controls such as pavement, barriers, and slurry walls are designed to limit access and exposure to contamination or are designed to eliminate further migration of the contamination. Engineering controls must always be used in conjunction with institutional controls to ensure that the engineering controls are properly monitored and maintained and that the DEP has access to inspect the controls. Ending site cleanup under No Further Action with Conditions provisions as an alternative to a complete cleanup may result in significant cleanup cost savings. Owners of non-eligible sites (or eligible sites that have cost share requirements or funding caps that will likely be reached) should give thorough consideration to this alternative to cleanup completion, as it could considerably reduce their cleanup cost. In most cases it is necessary for the contamination to be confined to the property that was the source of contamination to qualify for an NFA with Conditions site closure, since the source property owner cannot impose institutional controls on neighboring property owners. Therefore, an alternative to be considered for sites that have contamination extending beyond the property boundaries is to perform a partial cleanup. Once contamination is confined to the source area (within site boundaries), the site may be eligible for NFA with Conditions. This approach could also result in considerable cost savings compared to a complete cleanup of the source site to the cleanup target levels for soil and groundwater. Site owners should be aware that deed restrictions, while not necessarily permanent, may not be removed without the DEPs consent. Natural attenuation processes (see page 22) will continue at the site after a No Further Action with Conditions is issued by the DEP. Supplemental assessment may be performed in the future to demonstrate that no residual contamination remains, and, if this is the case, the DEP may remove the requirement for deed restrictions. Site owners should also be aware that sites that are eligible for funding assistance from the Inland Protection Trust Fund do not lose eligibility if they agree to complete the cleanup with No Further Action with Conditions. The residual contamination remains eligible for future consideration for funding assistance for supplemental assessment or cleanup. The DEP has created a registry of sites that have received an NFA with Conditions and have engineering and/or institutional controls in place. To view the registry or to find out more information regarding institutional controls, see DEPs Contaminated Soils Forum Webpage at: www.dep.state.fl.us/waste/ catagories/csf/default. 24

Risk Assessment
Rule 62-770.650, F.A.C.
If a responsible party wishes to use cleanup goals different from the Groundwater and Soil Cleanup Target Levels established in Rule 62-777, F.A.C. (See Standards, page 11), then a risk assessment may be performed to justify those alternate cleanup goals. It is important to note that Rule 62-770 requires that a proposal to conduct a risk assessment be made to the DEP as one of the recommendations of the site assessment report, and the DEP must concur with that recommendation before a risk assessment is initiated. In some cases deed restrictions will be necessary to ensure the risk assessment exposure assumptions will remain constant. Because a risk assessment can be time consuming and costly, in most cases it is more appropriate and expeditious to utilize the No Further Action with Conditions provisions of Rule 62-770 (see page 24) rather than to conduct a risk assessment. A risk assessment will take into account actual site-specific exposure parameters and/or toxicity data in order to estimate the risk posed to human health or the environment 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 environmental receptors for all exposure pathways, actual or potential exposure factors such as duration and frequency, and established health-based values for all contaminants. A toxicity assessment examines the health and environmental impacts associated with exposure to: potable water, including ingestion, contact with skin, and inhalation of vapors and mists, non-potable water, which includes irrigation water and the crops to which it is applied, soil, including inhalation of dusts and consumption of crops grown in contaminated soil, surface water, which includes exposure through recreational use, the consumption of fish, and effects on freshwater or marine life and the food chain. A risk characterization may combine all of these elements to calculate alternative cleanup goals. These alternative cleanup goals must consider all available scientific data, be protective of non-carcinogenic effects, and correspond to a cumulative lifetime risk of one excess cancer incidence in a million or less. Institutional controls (deed restrictions) are often necessary to ensure the site-specific exposure assumptions presented in the risk assessment will remain in perpetuity.

25

Time Line
The amount of time it may take to assess and clean up a site which has been contaminated by a petroleum discharge may take from several months to well over ten years, based upon the severity of the extent and magnitude of contamination, as well as the strategies utilized for cleanup. The average cost for assessment and cleanup is typically $300,000, but some sites can cost millions of dollars to cleanup. The timeline presented below may be representative of a worst-case assessment and cleanup scenario a site with soils and groundwater which are impacted by large amounts of petroleum contamination. Also, the timeline does not take into effect additional preparation or review time which is required in the event that an incomplete report is submitted by the cleanup contractor. Incomplete or improper assessment, cleanup, or reporting will further delay the cleanup schedule and may also make the Responsible Party subject to enforcement action.

Beginning of Timeline: Discovery of Discharge

w
Contamination Reporting: IMMEDIATE

w
Source Removal
To be initiated within three days of discovery; Report to be submitted within 60 days of completion of soil removal.

w
Site Assessment
To be initiated within 30 days of discovery. Report due within 270 days of discovery of contamination.

w
Regulatory Review of Site Assessment Report
30 days

w
To be submitted within 90 days of approval of a Site Assessment Report.
26

w w w w w

Remedial Action Plan

End of Timeline: CLEANUP COMPLETE

Regulatory Review of No Further Action Proposal

60 days

Monitored Natural Attenuation

Beginning at end of Active Remediation Period and extending for a period of up to 5 years.

Regulatory Review of Monitoring Only Plan

60 days

Active Remediation
Site specific; typically 1 to 5 years.

Construction and Initiation of Active Remediation System or Strategy

Within 120 days of approval of Remedial Action Plan.

w w w w w

Regulatory Review of Remedial Action Plan

60 days
27

w w w w w

The Cleanup Process

Key Points

Follow notification requirements when a petroleum release occurs so that proper authorities can perform or oversee emergency response. The proper initial characterization and removal of contaminant source material (free product and soils) as soon as possible after a discharge may greatly reduce the amount of time and cost required for complete cleanup. Direct-push sampling techniques coupled with an on-site mobile laboratory may be a cost-effective site assessment strategy for sites with large contaminant plumes. A thorough and complete site assessment must be performed in order to determine the most cost-effective and technically practicable remediation strategy to address contamination. Follow the Petroleum Contamination Site Cleanup Criteria of Chapter 62-770, Florida Administrative Code, and additional local requirements in order to achieve successful cleanup, reduce liability, and preserve the value of your property. And, most importantly:

An ounce of Prevention is worth a pound of Cure!

YO U R

Follow storage tank registration and maintenance requirements as well as operational Best Management Practices in order to avoid a discharge of petroleum product to the environment! For more information, see Your Storage Tank Facility Inspection Guide, available from the DEP at www.dep.state.fl.us/waste/categories/pcp/default.htm.
HOW

PET RO TA N L E U M S K F TO INS PEC ACILITY RAGE TION GUI DE

WEL L PET R O L D O YO U EU KN DIS T R I B M S T O R O W YO UTIO U A N S GE AND R YST EM?

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Florida Department of Environmental Protection (DEP) Division of Waste Management Bureau of Petroleum Storage Systems
2600 Blair Road Tallahassee, FL 32399 Phone 850-921-5953 Fax 850-414-7797

Department of Planning and Environmental Protection Pollution Prevention Division

218 S. W. First Avenue Fort Lauderdale, FL 33301 Phone 954-519-1260 Fax 954-765-4804

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 Floridas Petroleum Cleanup Program. 2002 by the Florida Department of Environmental Protection