Broward
Environmental
Remediation
An Official Quarterly Publication of
Broward County’s Pollution Prevention Division
Monitoring
Inside This Issue
Well Abandonment
Expectations and Issues.....1
ATC Evaluations….……...3
Background Concentration
Evaluation for Arsenic in
Soil..……………………...4
Health & Safety Plans for
DWM Programs.................5
PRP Facilitator Option…...6
Times
Summer 2016
Well Abandonment Expectations and Issues
Proper well abandonment (WA) of monitoring and treatment wells is
required to remove a potential pathway of surficial contamination to the
surficial aquifer. Surface restoration is important to minimize health &
safety issues, to reduce a negative impact of the cleanup activities to the
appearance of the facility, and to ensure the soundness of patching/pavement
in areas subject to vehicular traffic. This article discusses areas of concern
over observed WA practices and the potential for legacy repairs if the
abandonment procedures are not performed properly and are not
appropriately documented. Issues have been noted at both program and nonprogram sites and are discussed below:
Un-abandoned wells: One of the most common issues encountered during
post WA inspections is un-abandoned wells. Wells were often covered or
partially hidden, but many were in plain sight. Some wells were found not
to have been abandoned due to misidentification of the well as a utility clean
out or related item. Field crews sent to abandon wells should be supplied
with scaled site diagrams and/or site photographs with current landmarks
and a measuring wheel or equivalent to aid in finding all the wells requiring
abandonment. In many instances a metal detector should be included as part
of the equipment load-out for the environmental contractor to help find
monitor wells in landscaped areas. Note also that treatment wells such as air
sparge, soil vapor extraction, or recovery wells also require abandonment.
Note further that monitor and treatment wells must be abandoned prior to
construction activities to prevent route of entry of contaminants to the
aquifer. This issue has been noted particularly at Non-Program sites.
Abandonment procedure: Proper WA procedures must be followed to
minimize the migrations pathway of a spill to the surficial aquifer and, in
some cases, to maintain the pressure of artesian aquifers. It has been noted
on several abandonment inspections that a tremmie-pipe or similar method
has not been used to ensure that the grout was placed from the bottom to the
top of the screened interval. The required methods of grout placement
includes the use of a tremmie-pipe, forced pressure, or equivalent method.
The Division has noted and commented on the use of improper grout
emplacement techniques during WA site inspections. The grout must be
properly mixed to allow flow through the pipe and reduce the possibility of
a blockage that may prevent the entire screened interval to be plugged with
grout. The grout mixture must consist of 5.2 to 5.5 gallons of water per sack
of Portland cement; or a mixture of 6 gallons of water per sack of Portland
cement, and 3 to 7.5 pounds of Bentonite (to reduce shrinkage). The
Bentonite should not exceed 8% by weight of the grout mixture.
continued on Page 2……
Broward County Board of County Commissioners
Mark D. Bogen • Beam Furr • Dale V.C. Holness • Marty Kiar • Chip LaMarca • Tim Ryan • Barbara Sharief • Lois Wexler
www.broward.org
Broward Environmental Remediation
Times
Summer 2016
……..continued from Page 1
Well not topped off during
abandonment
Note that the grout shrinks during its curing process and therefore the grouted wells
should be checked prior to leaving the site as it is not unusual to find wells where
the grout level has sunk below the well screen, leaving it exposed. Therefore the
wells should be topped off with grout to address this issue. In numerous post-WA
inspections, the Division has noted and followed up on the observation of wells
having so much grout shrinkage that the well screens were subsequently found to
be exposed, providing no protection to the aquifer. In these cases, re-mobilization
to the site was necessary, adding additional costs to the project. Please reference
Rule 62-532.500 Florida Administrative Code, South Florida Water Management
District Rule 40E-3.531(3), and Broward County’s Minimum Criteria for
Monitoring Well Installation and Sampling when planning for and performing WA
field activities and subsequent reporting.
Surface Restoration Issues:
Well abandoned and matched with
surrounding area
Well abandoned but vault not
removed
During post-WA inspections conducted by the Division, cracked, unstable, and
wobbly well pads have been left behind. Bolt-down manholes have been found
grouted but the bolts left sticking up almost an inch in a parking area. Well lids
have been found grouted in place but with the lip exposed causing a trip hazard.
Improperly mixed concrete used for some patches were found to be weak and
poorly finished. These pads would not have lasted for any appreciable time in the
high-traffic environments common to most cleanup sites. Cases have been found
where the contractor claimed to remove monitor well vaults when it was
discovered the vaults were covered with concrete. Sloppy disposal of grout,
concrete, etc., has been observed on several sites. The Division has received
complaints from site owners/operators regarding the surface restoration issues
mentioned above, requiring follow-up on part of the contractor. In the case of
program sites, the follow-up repairs could not be reimbursed by the Petroleum
Restoration Program. As a reminder regarding well pad removal from Program
sites, the cost of well pad removal is included in Pay Items 7-1 through 7-4 of the
Schedule of Pay Items Rate Sheet and should therefore be performed as a matter
of course.
If you have any questions on this article you may contact John J. Gomolka, P.G.
at [email protected] or (954) 519-1279.
Broward County Board of County Commissioners
Mark D. Bogen • Beam Furr • Dale V.C. Holness • Marty Kiar • Chip LaMarca • Tim Ryan • Barbara Sharief • Lois Wexler
www.broward.org
Page 2
Bolts left sticking up; tripping
hazard
Surface restoration is important to minimize health & safety issues and to ensure
the soundness and durability of patching/pavement in areas subject to vehicular
traffic. It should also be mentioned that surface restoration of the well pad areas
leaves a lasting visual impression to the public and, if improperly done, can impart
a negative overall impression of the environmental cleanup industry. Patching of
former well-pad areas shall be done to provide a best match to the existing cover.
There have been examples where provisions of concrete patches in asphalted areas
have not been accepted by site owners; necessitating an unpaid mobilization to the
site for repairs to match existing conditions. Asphalted patches have been found
to be placed over improperly compacted backfill material, resulting in a patch that
will settle over time to create a depression that may break up and create a broken
surface that is unsightly and unstable.
Broward Environmental Remediation
Times
Summer 2016
Agency Term Contractor Evaluations
______________________
“The revised evaluation forms
streamline and make the rating
process more objective while
incorporating the issues of
most concern to the RP/SOs.”
______________________
ATCs, do you know your score? Do you even know what criteria are used to
calculate your score? How will you know how to earn the points needed to
maximize your competitiveness unless you know the rules of the game?
The scoring system is part of Rule 62-772.300, Florida Administrative Code
(F.A.C.). A change to Rule 62-772.300(1), F.A.C., revised the scoring system
and went into effect April 6, 2016. The revised rule requires ATC performance
evaluations, with input from the responsible party (RP) and/or site owner (SO),
at least after completion of each task assignment or purchase order. The forms
used to conduct the evaluations are available at
http://www.flrules.org/Gateway/reference.asp?No=Ref-05720 and
http://www.flrules.org/Gateway/reference.asp?No=Ref-06667.
Each ATC should become familiar with the forms. The scores will be
incorporated into the FDEP's contractor selection formula.
The RPs and/or SOs will have the opportunity to complete a one-page
questionnaire consisting of seven (7) categories: Communication, sufficient
notice, effective oversight, safety procedures, damage control, site restoration and
compliance with site specific requirements. The RP/SO input counts ten percent
of the overall ATC rating.
Site Managers will complete a four page evaluation form consisting of six (6)
weighted categories:
Project Timeliness (10%), Invoicing (15%), Reports (15%), Communication
(10%), Cost Control (15%), and Quality and Technical Competence (25%).
The revised evaluation forms streamline and make the rating process more
objective while incorporating the issues of most concern to the RP/SOs.
Everyone needs to know how to score to win, whether playing a game or running
a business!
Questions regarding this article can be directed to John J. Moore at (954) 5190307 or [email protected].
We are excited to present the latest edition of the newsletter. If you or someone
you know has recently changed firms, moved to a new location, changed e-mail
addresses or are unable to receive this newsletter, please contact Probas Adak,
P.E. ([email protected]) with your new contact information.
Broward County Board of County Commissioners
Mark D. Bogen • Beam Furr • Dale V.C. Holness • Marty Kiar • Chip LaMarca • Tim Ryan • Barbara Sharief • Lois Wexler
www.broward.org
Page 3
UPDATE YOUR CONTACT INFO
Broward Environmental Remediation
Times
Summer 2016
Background Concentration Evaluation for Arsenic in Soil
Teaf et al. investigated a site located in Hillsborough County where extensive soil sampling revealed no evidence of localized
source(s) of arsenic releases. Analyses were presented to support the position that the observed site-wide arsenic
concentrations were the result of naturally occurring background conditions. Natural background concentrations refer to the
ambient concentrations of arsenic in soils that are not caused by human activities. Teaf et al. evaluated arsenic background
concentrations in a geographic “belt” that included the Hillsborough site, since arsenic concentrations in soil samples from
the Hillsborough site were detected above the Florida Default Residential Exposure Soil Cleanup Target Level (SCTL) of
2.1 mg/kg. FDEP Department Rules require rehabilitation of the site to achieve the less stringent of 2.1 mg/kg and the local
background concentration.
According to Teaf et al., natural background occurrences are likely if, along with other lines of evidence, there is a low
degree of statistical variability of arsenic concentrations across the site. Specifically, there should be a close agreement
between the average site-wide concentration and the 95% upper confidence limit average concentration (UCL). The sitewide mean concentration for 2,031 soil samples from the Hillsborough County site was 2.4 mg/kg and the site-wide UCL
was 2.8 mg/kg. The calculation demonstrates with 95% confidence that the average arsenic concentration of the soil
represented by the data set is at or below the UCL value of 2.8 mg/kg.
Teaf et al. then proposed that the appropriate site-specific SCTL for cleanup should be the UCL value of 2.8 mg/kg, instead
of the default value of 2.1 mg/kg. In addition to the low degree of statistical variability, the 2.8 mg/kg for the Site represents
a very nominal increased cancer risk (1.3 in one million) as compared with the current FDEP default residential SCTL of 2.1
mg/kg cancer risk of 1.0 in one million. FDEP acceptance of the site-specific SCTL value of 2.8 mg/kg for the Hillsborough
County site would allow for No Further Action (NFA) for soil without controls.
Applying Teaf et al. findings to a golf course in the Coral Springs, the estimated 95% UCL value of 6.3 mg/kg is not close
to the average concentration across the site (4.1 mg/kg). Therefore, the data analysis does not support a low degree of
statistical variability of arsenic concentrations across the site to substantiate the case for background occurrences. In addition,
it is known that during the operation of the golf course, multiple arsenic-containing herbicides and/or pesticides were applied
across the course. So, the observed arsenic contamination is anthropogenic and not due to naturally background occurrences.
The Teaf et al. analyses is one useful tool to determine the possibility of background occurrences for cases where there are
no historical activities on the site that are known or expected to have resulted in arsenic releases.
Reference: Teaf, Christopher M.; Covert, Douglas J.; Coleman, R. Marie; Petrovich, Michael; Murali, R.S.; and Yarina,
Vince (2007) "Risk And Background Evaluation For Arsenic In Soil At A Planned Residential Development," Proceedings
of the Annual International Conference on Soils, Sediments, Water and Energy: Vol. 12, Article 8. [Teaf et al]
•
Please note that FDEP Guidance for Comparing Background and Site Chemical Concentrations in Soil can be
found online at:
https://www.dep.state.fl.us/waste/quick_topics/publications/wc/Soil_Background_Guidance_Jan12.pdf
•
FDEP approved 95% UCL calculators can be found under the following link:
http://www.dep.state.fl.us/waste/categories/wc/pages/ProgramTechnicalSupport.htm
 FL-UCL calculator can be downloaded as a zip file (look under “Highlights” on the right side of the above
link)
 USEPA version of the UCL calculator, called Pro-UCL, can be found under “Calculators” by clicking on
the same link
Broward County Board of County Commissioners
Mark D. Bogen • Beam Furr • Dale V.C. Holness • Marty Kiar • Chip LaMarca • Tim Ryan • Barbara Sharief • Lois Wexler
www.broward.org
Page 4
Questions regarding this article can be directed to Seree Jairam, P.E., at (954) 519-1467 or [email protected].
Broward Environmental Remediation
Times
Summer 2016
Health & Safety Plans for DWM Programs
(Recommended minimum requirements)
“Description of the specific
work areas and evaluation of
risks associated with site with
each
activity
conducted
included, but not limited to onsite and off-site exposure to
contaminants.”
In an effort to consistently provide support for all Division of Waste
Management cleanup programs, all cleanup contractors working under term
contracts for the Department shall include at a minimum the following key
elements in their Health and Safety Plans (HASPs):
•
•
•
•
•
•
•
Site description including availability of resources such as electricity, roads,
etc.
Description of the specific work areas and evaluation of risks associated with
site with each activity conducted included, but not limited to on-site and offsite exposure to contaminants.
List of key personnel and alternates responsible for site safety, response
operations and protection of public health.
Establishment of procedures to control site access.
Specific description of levels of protection (list items) to be worn by
personnel in the work area.
Description of decontamination procedures for personnel and equipment
Establishment of site specific emergency procedures, including route to
nearest medical facility and emergency care for on-site injuries
Each and every site Health and Safety Plan (HASP) shall be consistent
with:
•
•
•
•
•
•
OSHA Regulations, particularly with 29CFR-1910 and 1926
EPA Order 1440.2 – Health and Safety Requirements for Employees
engaged in Field Activities
EPA Standard Operating Safety Guide (1984)
EPA Order 1440.3 – Respiratory Protection
NIOSH Occupational Safety and Health Guidance Manual for Hazardous
Waste Site Activities (1985)
Appropriate State and local government regulations
For a complete review, please check the following link:
http://www.dep.state.fl.us/waste/categories/pcp/pages/safety.htm
30th Annual Environmental
Permitting Summer School
NOTE: Each and every site Health and Safety Plan must be revised to
address any additions and/or changes in planned activity at the site.
July 19-22, 2016 at Orlando, FL
http://floridaenet.com/
•
•
•
•
Site Specific HASP example - AMEC
Site Specific HASP example - JSA
Site Specific HASP example - AET
Site Specific HASP example - MACTEC
Broward County Board of County Commissioners
Mark D. Bogen • Beam Furr • Dale V.C. Holness • Marty Kiar • Chip LaMarca • Tim Ryan • Barbara Sharief • Lois Wexler
www.broward.org
Page 5
While there are numerous HASPs in FDEP OCULUS that can be used as
templates, a number of scanned HASP examples for common activities can
be found below. Follow the link and click the "PUBLIC OCULUS LOGIN"
button to access the document:
Broward Environmental Remediation
Times
Summer 2016
• Site Specific HASP example - LFR
• Site Specific HASP example - FL Geo Eng
Other Documents
• Memo: Health and Safety for Programs under Divisional Management
• Health & Safety Plan Requirements
• DWM Contractor Safety Handbook
“The PRP Facilitator option
provides qualifying property
owners and responsible parties
with an individual point of
contact known as a PRP
Facilitator.”
PRP Facilitator Option
The Petroleum Restoration Program (PRP) is excited to announce the PRP
Facilitator option to assist property owners and responsible parties with at
least twenty (20) program eligible sites. The PRP Facilitator option
provides qualifying property owners and responsible parties with an
individual point of contact known as a PRP Facilitator (Facilitator).
Individual site managers will still be overseeing the administrative and
technical aspects of site cleanup; however, the Facilitator will able to
provide program support on a more global basis.
The Facilitator option will also assist the PRP management in identifying
any issues with Agency Term Contractors (ATCs) or PRP staff in order to
address them in a timely manner. If you are interested in this option or if
you have questions please contact:
Rebecca Marx, Environmental Administrator, at (850) 245-8892
or [email protected]; or
Grant Willis, Environmental Consultant, at (850) 245-8886
or [email protected].
In order to be assigned a PRP Facilitator please provide a list of your funding
eligible sites.
Any questions regarding this and the previous article can be directed to
Matthew M. Theisen, P.G., at (954) 519-0323 or [email protected].
Hurricane season began on June 1st. Now is the time to update your
Emergency Family Plan. Bookmark the Home Damage Assessment
application on your mobile device. Subscribe to Emergency Updates.
Start assembling items for your hurricane supply kit using the 8-Week
Shopping Guide. Please check out additional details on Broward County’s
dedicated
Hurricane
preparation
resource
webpage:
http://www.broward.org/Hurricane/Pages/Default.aspx
Broward County Board of County Commissioners
Mark D. Bogen • Beam Furr • Dale V.C. Holness • Marty Kiar • Chip LaMarca • Tim Ryan • Barbara Sharief • Lois Wexler
www.broward.org
Page 6
2016 HURRICANE SEASON