That is what Contamination Assessments used to be called in Florida. But then they were renamed Site Assessments, which can be confused with Environmental Site Assessments (Phase I and II – see our other blog articles specific to those types of projects). To avoid confusion, we will stick with the name Contamination Assessment (CA). They became regulatory requirements in Florida in the 1980’s to primarily address contamination from underground and above ground fuel and oil storage tanks. These CAs are required when contaminant levels in the soil or groundwater exceed the State Cleanup Target Levels. They are designed to determine the extent of contamination in the soil and groundwater both horizontally and vertically. Often, the contamination is originally discovered during tank closure, after a leak, from a spill, etcetera.
Which regulatory agencies require the CAs? The lead agency is the Florida Department of Environmental Protection (FDEP, www.fdep.gov). However, several counties (primarily the larger urban centers) have a contract to administer the cleanup program for the FDEP. To determine if that is the case for your site, contact the district office of the FDEP which governs your county.
Which regulation requires CAs? Chapter 62-780 of the Florida Administrative Code (F.A.C.) does. All the detailed requirements are provided in that rule. For questions, contact the FDEP or county administering the cleanup program. The actual scope of work depends on the situation. Certain things affect the scope such as level of contamination, type of petroleum product, history, action taken to clean it up, and whether the soil, groundwater, or both are affected. Action taken could involve initial response, pumping out product, limited soil removal, and more.
Details of CAs will be discussed in another blog article. Just be warned that CAs usually take time. There are certain periods of time required to complete each step. You are given deadlines to complete things and the regulatory agencies have deadlines to review and respond to each document or response you submit. The whole process can easily drag into a year or more.
But for the moment, let’s say you have finished your CA and submitted it to the FDEP or county. What are the potential outcomes? First, additional work (i.e., more testing, information, or clarifications) may be required. Next, let’s say you hit the lottery and you receive approval for No Further Action – you are done! Alternatively, you do not hit the lottery and a Remedial Action Plan is required, followed by Remedial Action, and of course, another report. Finally, there is a low level of contamination which results in potential natural attenuation (the site cleans up on its own). In that case, you are required to complete Natural Attenuation Monitoring, which is done at regular intervals during each year for a two year or longer period of time.
So there you have it – a very brief introduction to Contamination Assessments in Florida. If you need any help, Environmental Safety Consultants (www.escflorida.com) can assist. We have the credentials and experience to answer your questions and steer you in the right direction. We are a Florida-licensed Engineering business with a Professional Engineer (P.E.), environmental scientists, and 30 years of experience completing CAs. We are just a telephone call (800-226-1735) or an e-mail away ([email protected]). Contact us today!