Broward Environmental Remediation

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1 Broward Environmental Remediation An Official Quarterly Publication of Broward County s Environmental Engineering and Permitting Division Transportation and Disposal of Additional Soil Inside This Issue T&D of Additional Soil..1 Remedial System Piping. 2 Irrigation Wells at Contaminated Sites. 3 CPE Clarification 4 23 rd FRC in Orlando... 4 Superfund Report... 5 The Petroleum Restoration Program (PRP) has been very clear that changes to a work scope cannot be authorized after-the-fact. Both Attachment A of the PRP Scope of Work and the Request for Change (RFC) form include statements requiring changes in quantities or costs be processed through a change order prior to initiating work. The PRP however does recognize that during source removal it is possible to incur an overage which is not detected until after the weight tickets have been tallied. Because of this, the PRP recently established a policy in which a request for additional Transportation and Disposal costs may be authorized after-the-fact. In order for the PRP to evaluate such an after-the-fact RFC however, the following criteria must be met: 1) The RFC must be received by the site manager within two working days of the date the additional soil (overage) was transported from the site. 2) The volume of soil requested in the RFC does not exceed 20% of the total volume authorized in the Purchase Order. Since these requests must be submitted within two days of the soil being transported from the site and NOT from receipt of the weight tickets, the ATC must remain mindful not only of the pre-authorized tonnage to be disposed, but of the ongoing total of material removed. The ATC must therefore maintain regular communication with the disposal facility to ascertain tonnages in real time. A copy of the September 13, 2017 Memorandum outlining this procedure can be found at the following link. You can also find a copy of this Memorandum in the Request for Change (RFC) - Change Orders section of the Templates, Forms, Tools, and Guidance page of PRP s website. Any questions regarding this article can be directed to David Singleton, P.G. at (954) or dsingleton@broward.org. PRP Lowers Funding Eligibility Score to 20 Effective October 27, 2017, the Petroleum Restoration Program (PRP) will lower the priority score funding threshold from 27 to 20. PRP will begin contacting site owners and Agency Term Contractors, as applicable, concerning site access, deductibles due, cost-share agreements and work assignments. Page 1

2 Remedial System Piping Installation and Related Issues Cleanup procedures utilized by the Florida Department of Environmental Protection s (FDEP) Petroleum Restoration Program (PRP) include the construction of mechanical cleanup systems. There are many aspects involved with construction of these systems that must come together for a successful system installation and the subsequent operations and maintenance (O&M) of the system. This article will focus on some aspects of below-grade remedial system piping installation. Piping runs designed for PRP cleanup sites often consist of Schedule 40 or Schedule 80 polyvinyl chloride (PVC) piping. The difference between the two types of piping are mainly in the wall thickness, and differing capabilities regarding pressure, flow, sun resistance, and durability (i.e. ability to withstand backfilling and compaction). Graphic showing various PVC schedule types Photo of mismatched schedule 40 and schedule 80 piping and fittings Photo after the contractor replaced schedule 40 fittings to match the piping Due to the differences between Schedule 40 and Schedule 80 piping and noting that schedule 80 will have a smaller cross sectional area), it is important for the contractor to ensure that remedial system components are installed as specified in the Remedial Action Plan, that the associated Construction Drawings are consistent with Petroleum Restoration Program requirements, and that the remedial systems have the best chance of performing as designed. Failure to install system equipment and appurtenances per the design specifications can lead to performance issues during O&M of the system and contractual issues that would impact remuneration from the PRP. Also, PVC piping is not joined together with what is traditionally thought of as a glue; rather, a PVC solvent primer (usually purple) is swabbed on the ends to be joined to soften the materials to be joined, and then a solvent cement is added to chemically bond (solvent weld) the materials together. The use of the two piping types could, in the event of a failure or performance investigation, prompt the question whether the cementing procedure was appropriate for the types of material used. In a recent site inspection, the Division observed a piping installation whereby Schedule 40 couplings, T-fittings, and elbows being used to connect sections of Schedule 80 PVC piping prior to trench backfilling. This automatically put weaker points within the piping run and would complicate trouble-shooting if some of the treatment wells were found not to perform adequately and also represented a contractual issue. Schedule 80 PVC pipe had been specified in the RAP and associated Air Sparge Well Detail. This required resolution by the Agency Term Contractor and their subcontractor to perform repair and replacement work, incurring additional time, cost, and effort for both parties. From a contractual perspective, Section 19 part A.4 of the Amended and Restated ATC States: Regardless of authorization to retain subcontractors or assign work, Contractor remains responsible for all Work Assignments under this Contract. So it is important for the ATC to provide sufficient oversight of subcontractors to ensure compliance with PRP requirements and pertinent approved design documents. If you have questions or need additional information regarding this article please contact John J. Gomolka, P.G., at (954) or jgomolka@broward.org. Page 2

3 Irrigation Wells at Contaminated Sites For the protection of public health, use of contaminated groundwater for irrigation wells (wells) is generally prohibited at properties subject to an institutional control such as a Restrictive Covenant (RC). However, use of existing wells or construction of new wells for Irrigation Scenarios (ISC) sites are approved by the FDEP s Division of Waste Management (DWM) based on site specific exposure scenarios analysis presented in the letter from the University of Florida to Ms. Ligia- Mora Applegate dated January 14, 2009; and Modification Letter dated June 28, 2016 (Letter) ( ISC includes sites using contaminated groundwater to irrigate lawns, ornamental beds, or vegetable crops. The Letter essentially estimates alternate irrigation cleanup target levels (IGCTLs) for contaminants of concern in the groundwater for each ISC as allowed by Chapter , Florida Administrative Code. The exposure models used in the study for lawns and ornamental beds consider potential intake of contaminants in groundwater through inhalation, dermal contact, and incidental ingestion. The Briggs model was used for vegetable crops to estimate the uptake of a contaminant into produce from known concentrations in irrigation water. The following table compares IGCTLs from the study and groundwater cleanup target levels (GCTLs) for selected contaminants: Contaminants IGCTLS GCTLs Residential Industrial Produce µg/l µg/l µg/l µg/l Arsenic NA 10 Benzene Naphthalene Pyrene # 210 Vinyl chloride NA = Not applicable. The Briggs plant uptake model utilized for this scenario is not applicable to inorganic chemicals. # = These chemicals are highly unlikely to be taken up by plants from water. The Produce scenario is not of concern for these chemicals. View of an irrigation well at a contaminated site Exposure Scenario Residential Industrial Produce Receptors Residents using contaminated water for lawn and ornamental bed irrigation, including exposure from recreational use of the lawn sprinklers by children. Landscape maintenance workers using contaminated water for the irrigation of lawns and ornamental beds at commercial facilities Residents who use contaminated water to grow fruit and vegetables for personal consumption So, ISC sites where the contaminant in groundwater meets the applicable IGCTLs may continue using existing wells for irrigation. For the case where a RC is used as the institutional control to prohibit groundwater use, the property owner would record their specific ISC land use in the property deed to allow for well use exemption at their site. A RC revision may be required to switch ISC (e.g. sites with contaminants meeting the industrial IGCTLs but exceeding the residential IGCTLs may not switch from irrigating ornamental beds to irrigating lawns). Any questions regarding this article can be directed to Seree Jairam, at (954) or sjairam@broward.org. Page 3

4 Contractor Performance Evaluation Clarification It is standard Petroleum Restoration Program (PRP) procedure to evaluate an Agency Term Contractor (ATC) upon completion of every Purchase Order. There are currently six main performance categories within each Contractor Performance Evaluation (CPE). The intent of this article is to provide clarification regarding Performance Category 1 (Project Timeliness). Specifically, question (b.) which states Notices of upcoming field work were provided within the time frames required by applicable rules..minimum seven (7) days notice for ALL upcoming fieldwork. While Table A of Chapter , Florida Administrative Code (FAC) specifies notification be provided within seven days but not less than 24 hours prior to performing field activity, this CPE question refers to a specific provison acknowledged in Attachment A (Scope of Work) of each Purchase Order. Specifically the tab titled Notice of Field Activities which declares The Contractor must provide written notification ( s are acceptable) of field activities at least seven (7) calendar days prior to the commencement of work to all applicable parties including the PRP site manager, PRP Inspector (PRP_Inspector@dep.state.fl.us), site operator, site owner, RP and affected offsite property owners. It is therefore a requirement of each Purchase Order that the ATC provide a minimum seven (7) days notice for ALL upcoming fieldwork. If just one notice is submitted less than seven days prior to scheduled field work, a score of 2 cannot be awarded for this question in the CPE. Any questions regarding this article can be directed to David Singleton, P.G. at (954) or dsingleton@broward.org. Twenty Third Annual Florida Remediation Conference Held in Orlando The twenty-third annual Florida Remediation Conference (FRC) was presented on December 7 th and 8 th at the Rosen Centre Hotel by the National Technical Communications Company, Inc., which publishes the Florida Specifier. Over 500 attendees, including staff from Broward County Cleanup and Waste Regulation Section, were on hand to hear over 50 speakers discuss the latest advances in existing and innovative remedial strategies, and the current regulatory atmosphere. Over 90 exhibitors including environmental laboratories, drilling firms, trade groups and environmental consultants showed cased their products and services. During the two-day conference, speakers were generally grouped into the following themes: Innovative assessment and remediation strategies, emerging contaminants of concern, applications of in-situ assessment and remedial strategies, case studies on petroleum remediation, thermal technologies and complex strategies, enhanced in-situ remediation applications, and conceptual site models. Of special interest was the Young Professionals Session specifically designed for 35-under professionals to share their perspectives on technical and management issues, and the speed talk session consisting of five minute talks on a variety of topics. As in past years, the regulatory panel discussion (Panel) specially caught the attention of the attendees. The Panel included Austin Hofmeister, Program Administrator for the Florida Department of Environmental Protection (FDEP) Petroleum Restoration Program (PRP); Teresa Booeshaghi, Program Administrator for the FDEP Waste Cleanup Program (WCP); Lynn Page 4

5 Walker,, with the FDEP Office of District and Business Support; and Wilbur Mayorga,, Miami-Dade County Chief of Environmental and Restoration Division. The current status of the PRP, WCP, and the Office of District and Business Support, as well as Miami-Dade County process and challenges for developing contaminated sites were discussed. For the past 23 years, the FRC has given consultants, laboratory, regulatory agencies, contractors, and suppliers the opportunity to introduce their knowledge, products and services as well as providing an opportunity for networking. To inquire about vendor opportunities or to make a presentation, in next year s conference contact Mike Eastman at mreast@enviro-net.com. Additional information may be found at the Enviro-Net website which also provides information on Florida s environmental issues and concerns: Questions regarding this article can be directed to Norman Arrazola, at (954) or narrazola@broward.org. EPA Superfund Remedy Report, Fifteenth Edition We wish Happy Holidays and a peaceful, prosperous New Year 2018 to all of the Broward Environmental Remediation Subscribers Lorenzo Fernandez, Fraser Mickle David Vanlandingham, John Moore John Gomolka, P.G. Probas Adak, The Environmental Protection Agency (EPA) prepares the Superfund Remedy Report (SRR) to provide information and analyses on remedies EPA selected to address contamination at Superfund National Priorities List and Superfund Alternative Approach sites. The SRR, Fifteenth Edition, was published by the EPA Office of Superfund Remediation and Technology Innovation in August This report is the latest in a series, prepared since 1991, on Superfund remedy selection. The report focuses on Superfund remedial actions selected in fiscal years 2012, 2013 and 2014, and on remedy trends since The report includes remedies selected in 308 decision documents (Records of Decision [RODs], ROD amendments, and Explanations of Significant Differences with changes to remedy components) signed in this three-year period. The SRR compiles data on overall remedy selection and remedies for source materials (such as soil and sediments), groundwater, surface water and air related to vapor intrusion. The report also analyzes media and contaminants for sites with remedies. The appendices summarize all of the remedy components selected for sources and groundwater in each decision document signed in 2012, 2013, and For more information on the SRR, please contact: Carlos Pachon Technology Integration and Information Branch PH: (703) pachon.carlos@epa.gov David Singleton, P.G. Wayne Trent Matthew Theisen, P.G. Seree Jairam, Jill Ryan Norman Arrazola, Copies of the current and previous versions of the SRR can be found in the following web link: Questions regarding this article can be directed to Probas Adak, at (954) or padak@broward.org. Page 5