Broward Environmental Remediation

Times March/April 2001 A bimonthly publication of Broward County’s Department

of Planning and Environmental Protection

University of Florida TREEO Center Announces Hands-OnField School for Petroleum Contamination Cleanup

The University of Florida’s Center for Training, Research and Education forEnvironmental Occupations (TREEO) is offering a Field School for Petroleum

Contamination Cleanup. The Field School is sponsored by the Florida Department of Environmental Protection’s(FDEP) Bureau of Petroleum Storage Systems and will be held at the TREEO Center in Gainesville.

The Field School is a hands-on training course demonstrating FDEP's appropriate procedures for collecting dataand for implementing quality assurance during assessment and remediation of petroleum-contaminated sites.Presented over two and one-half days, the Field School gives the opportunity to gain skills which can be usedimmediately on the job to comply with FDEP requirements. The Field School includes group workstationscovering groundwater sampling, soil boring, well installation, and direct push/groundwater sampling. A field tripto examine remediation systems at local petroleum-contaminated sites is also included.

Topics covered in the Field School include:

• Petroleum and its chemical constituents • An overview of site assessment and remedial process• Sampling • Remediation systems

Anyone involved in assessing and remediating petroleum contamination sites will benefit from this course,including consultants, government inspectors, petroleum storage personnel, and delegated local and countygovernment program managers. The course will be held starting in early March through mid-May and costs $195to attend (FDEP will pay this fee for participants from delegated local programs).

A full agenda and registration for the Field School, as well as additional information about TREEO, can be found atTREEO’s website: http://www.treeo.ufl.edu. For more information, please contact Carol Magary atcmagary@treeo.doce.ufl.edu or (352) 392-9570 ext. 109.

BROWARD COUNTY BOARD OF COUNTY COMMISSIONERS - An Equal Opportunity Employer and Provider of ServicesJosephus Eggelletion, Jr. Ben Graber Suzanne N. Gunzburger Kristin D. Jacobs Ilene Lieberman Lori Nance Parrish John E. Rodstrom, Jr. James A. Scott Diana Wasserman-Rubin

Visit us on the internet: www.broward.org/dpep

Global RBCA

Global RBCA (Risk-Based Corrective Action) is on the Florida Department of Environmental Protection’s legislativeagenda for this year.

Brief History

In 1986, language was added to Chapter 376 F.S., providing for cleanup of petroleum contamination “using the most cost-effective alternative that is technologically feasible and reliable, and that provides adequate protection of the public health,safety and welfare and minimizes environmental damage”. In 1994, the Florida Petroleum Efficiency Task Force (taskforce) was created by the legislature to make recommendations on ways to improve the efficiency of the petroleum cleanupprogram. The task force issued a final report to the DEP Secretary, which included a recommendation that Florida adoptRBCA for petroleum contamination sites. Later, language was added to the Florida Statutes to adopt RBCA for the othertwo state cleanup programs, namely the Dry Cleaning Solvent Cleanup Program and the Brownfields Cleanup Program.

Why RBCA?

RBCA is a decision-making process for determining the appropriate level of cleanup for contaminated soil andgroundwater based on protection of human health and the environment. Not every site needs to be cleaned up to drinkingwater standards. For example, a site with brackish groundwater may be treated differently than a site that is up gradientfrom a community that uses private potable wells for drinking water.

RBCA provides for the use of different tiers with different cleanup target levels which are matched to site conditions whileremaining protective of human health and the environment. It adds flexibility to the cleanup process by allowing theperson responsible for the cleanup to achieve the selected target level or to achieve exposure reduction (or elimination)through the use of institutional controls or containment methods. It also allows the responsible party the flexibility toselect the most cost-effective environmental cleanup plan from those that are suitable at the site so as to protect humanhealth and the environment.

It has been almost five years since the adoption of RBCA for petroleum cleanups. The results are clear; more sites arebeing cleaned up and the average cost of cleanups has decreased, while human health and the environment are still beingprotected.

Why “Global” RBCA?

Specific language in the Florida Statutes has adopted RBCA for the threeaforementioned cleanup programs. Global RBCA seeks to expand the benefits of thisdecision-making process to all sites. Currently, two sites next to each other, with thesame pollutants and extent of contamination, may be cleaned up to different levels justbecause one of them is a dry cleaner (or petroleum contaminated site or brownfieldsite) and the other is not.

Industry and the agricultural community have concerns and will probably object. In particular, they fear that enforcementmay be taken on exceedances of soil cleanup target levels (SCTLs), even though these exceedances may have originatedfrom the proper application of herbicides, pesticides, or other chemicals. However, the Department has already indicatedthat SCTLs will not be enforced on agricultural lands unless the land use changes.

Global RBCA should be supported for its benefits and its potential to make contamination cleanups more uniform acrossthe State.

Have any questions regarding this Article? Contact Lorenzo Fernandez, P.E. at (954) 519-1478 or via email atlfernandez@broward.org.

Feedback Forum

In order to improve the services which the EAR Section provides and better understand your needs, we need yourfeedback! Do you have a suggestion for the Times? Are there areas in which the Section can serve you better? Thereare several ways which you can provide us with your constructive criticism:

• We have provided a questionnaire for you on the last page of this Times edition. You may print it, fill it out,and return it via fax to Lorenzo Fernandez, P.E., at (954) 765-4804

• You may print the questionnaire, fill it out, and send it via U.S. mail to:Department of Planning and Environmental ProtectionATTN: Lorenzo Fernandez, P.E.218 S.W. 1st AvenueFort Lauderdale, FL 33301

• If you elect not to use the form, you may contact Mr. Fernandez via email at lfernandez@broward.org or viatelephone at (954) 519-1249.

PETRO-BOWL PLUSPetro-Bowl VI was held at Tradewinds park on Saturday, January 13, 2001. DPEP's Pollution Prevention Section wasthe host team this year where environmental consultants, petroleum contractors and regulators joined together withfamilies to compete in co-ed softball games for the prestigious Petro-Bowl trophy. South Florida Water ManagementDistrict was the proud champion this year. Other teams competing were Great Dane Petroleum, Earth Liquids, URSEnvironmental, H2O Environmental, IT Environmental, Petropac, and D. F. Consultants. Broward County Parks andRecreation co-sponsored the picnic shelter. A picnic, DJ, and bounce house also added to the day's family fun.

FDEP Holds Local Program Meeting and Training Class

On December 12, 2000, the Florida Department of Environmental Protection (FDEP) held a training session forLocal Program managers responsible for administering FDEP petroleum preapproval funds. Staff members ofBroward County’s Environmental Assessment and Remediation (EAR) Section attended the meeting, which was heldat the Radisson Plaza Hotel in Orlando. A lot of information regarding management and technical issues werepacked into this one-day session. Some main issues regarding Standard Operating Procedure and Work Orders arenoted below.

Work Order Issues

• Work Orders including analyses forpreburn or used oil group parametersshould include a listing of individualanalytical methods that will beperformed.

• Use a summary table to identify monitorwells that are proposed for sampling, theanalytical methods to be performed persample, and the associated costs.

• When water levels are to be obtained fornon-sampled wells, include these wellson the table for clarity.

• Quote and use the FDEP 10-29-98 memoin the work order descriptions and use inparticular when preparing the reportconclusions and recommendations.

• Specify the performance of the utilityclearance in the work order description. The costs for utility clearance is includedwithin the drilling setup line on the costtemplate.

Need additional information or have questions? Contact John Gomolka, P.G., at (954) 519-1279 or via email at jgomolka@broward.org.

Standard Operating Procedure (SOP) Issues

• The template item for performance of utilityclearances has been removed from the template. Atime/financial allowance for this activity has beenadded to the drilling setup template. In the eventof non-template drilling activities (such as directpush), consultants are still required to clear theutilities prior to work performance. An additionalmobilization is not to be added in conjunction withthe drilling setup template activity.

• In an effort to reduce the work-in-progress fundscarried by the consultants during construction/remediation projects, FDEP will allow consultantsto invoice for capital equipment purchases uponreceipt and inspection of the equipment. Consultants need to attach the vendor invoices totheir invoice. Consultants - Don’t forget! Youmust pay the subcontractors within net-30 daysfrom invoice payment.

• Regarding the Professional Land Surveys (PLS),the consultants should provide bidders with theFDEP list of items that are to be included (Section7.7 of the SOP). Make sure that the top of casings,not manholes, are measured. Oversight is notallowed for PLS.

• Groundwater sampling QA/QC issues. FDEPspecifically stated that consultants are not to worryabout duplicate sampling requirements regardlessof ComQAPP requirements.

Attention Consultants: A Great Way to Minimize Aged Work in Progress!!

The Florida Department of Environmental Protection (FDEP) recently reported that from June 2000 to December2000, a total of 169 Preapproval Program invoices generated by consultants for work completed within the sixteenLocal Program counties were rejected by the FDEP, and returned for correction. The following is a breakdown ofthe five general disapproval categories:

Reason NumberNot approved/not signed by Local Program 88Problems with Release of Claim form 38Incomplete backup information 27Incorrect invoice amount 13Invoice already paid/voided 3

Total 169

As is apparent by these statistics, over half the rejected invoices were returned because they were not approved bythe Local Program Site Manager. Please keep in mind, the FDEP has contracted with several counties, includingBroward, Dade, and Palm Beach Counties, to manage the petroleum cleanup program on a local level. It is requiredby Section 6.7 of the October 2000 Petroleum Preapproval Program Standard Operating Procedures (SOP) thatone original invoice (and all applicable backup material) be submitted to the Site Manager for review. For thoseLocal Program counties, Section 8.2.4 of the October 2000 SOP requires the invoice package be submitted directlyto the Local Program Site Manager. The Local Program Site Manager will review the invoice, and forward acceptedinvoices directly to the FDEP for final approval and payment.

For those consultants who work in both local program counties and directly for the FDEP, it is crucial to providethose employees responsible for invoicing with correct Site Manager information. By doing so, we should be ableto significantly reduce the number of unnecessary delays in payment for work completed.

If you have any questions regarding invoicing, refer to the SOP at http://www.dep.state.fl.us/dwm/programs/pcp/sopmanual.htm or contact your Local Program Site Manager.

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SECTION TWO: The Environmental Assessment and Remediation (EAR) Program

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