Screening Reports Prior to Site Assessment
Note: The screening reports are not a substitute for the 62-780, F.A.C. Site Assessment.
Phase I Environmental Site Assessment Report - Not required for DEP under 62-780, F.A.C.
Commonly referred to as an ESA or Phase I ESA. According to ASTM International (formerly the American Society for Testing and Materials), a Phase I Environmental Site Assessment is done to identify recognized environmental conditions in connection with a subject property. The intent of the report is to assess whether current or historical property uses have impacted the soil or groundwater beneath the property and could pose a threat to the environment and/or human health. A Phase I ESA can be used to satisfy the requirements of CERCLA’s (Comprehensive Environmental Response, Compensation and Liability Act) innocent landowner defense under All Appropriate Inquiries (AAI).
Phase II Environmental Site Assessment Report -Not required for DEP under 62-780, F.A.C.
Commonly referred to as a Phase II ESA. This is not the same as, nor does it meet the requirements of a Site Assessment Report under 62-780, F.A.C. According to ASTM International, a Phase II Environmental Site Assessment is done to evaluate known releases or likely release areas identified and/or to assess the presence or likely presence of substances. This type of assessment is typically performed only when Phase I results indicate potential contamination risks. It involves collecting samples from soil and groundwater, conducting laboratory tests on the samples collected, and interviewing previous owners or operators of the facility regarding past activities in order to identify any further potential sources of contamination. A Phase II ESA does not define the threshold levels at which target analytes pose a concern of significance to the user.
Activities, Plans and Reports for Cleanup under Chapter 62-780, F.A.C.
Emergency Source Removal Report (ESRR) – Site-specific step.
Within 24 hours of discovery of an unexpected or sudden discharge of pollutants or hazardous substances which based on the volume, mass, concentration, toxicity, or other characteristics of such discharge requires immediate action to alleviate a threat to human health, public safety, or the environment, or within 24 hours after being notified by the Department of such a condition, the Person Responsible for Site Rehabilitation (PRSR) shall commence an emergency response action. Within 60 days of completion of ESR, the PRSR shall submit an ESRR.
Site Assessment Report (SAR)- Required for DEP under 62-780, F.A.C. Cleanup.
Every person who has legal responsibility for site rehabilitation pursuant to chapter 376 or 403, F.S., is required to conduct a site assessment and submit a site assessment report as discussed in 62-780.600, F.A.C. A SAR is not interchangeable with a Phase II ESA. DEP requires certain standards for data collection and delineation of site soil and groundwater. Sampling under the current conditions is required. Notification of DEP of field sampling activities assist the site owner in knowing whether activities satisfy 62-780, F.A.C. requirements. If the SAR is insufficient, a Site Assessment Report Addendum may be requested.
Interim Source Removal Report (ISRR)- Site-specific step.
Note: Not applicable once Remedial Action Plan is submitted for DEP review and approval.
Any person responsible for site rehabilitation (PRSR) may conduct an interim source removal in accordance with this section. The objectives of the interim source removal are to remove specific known contaminant source(s) and provide temporary control to prevent or minimize contaminant migration, and to protect human health and the environment prior to the approval of a Remedial Action Plan (RAP) prepared and submitted pursuant to rule 62-780.700, F.A.C., or in the cleanup of de minimis discharges pursuant to rules 62-780.550 and 63.780.560, F.A.C.
Fate and Transport Model and Statistical Methods -Site-specific step done during site assessment.
See 62-780.610, F.A.C.
Fate and Transport models can be used to support an evaluation pursuant to the provisions of rules 62-780.650, 62-780.680, and 62-780.690, F.A.C. to simulate movement and degradation of contaminants in the aquifer over time and distance, taking into account attenuation mechanisms including biological, physical, and chemical processes.
Statistical Methods can be used to support an evaluation pursuant to the provisions of subparagraph 62-780.680(1)(b)1., 62-780.680(2)(b)1., or 62-780.680(3)(b)1., F.A.C. Methods must be appropriately based on statistical properties of the site-specific data set such as the number of samples, distribution of the data set, and the percent of non-detect sample results.
Risk Assessment Report (RAR) – Site-specific step during site assessment.
See 62-780.650, F.A.C.
Risk assessments determine how threatening a contaminated site is to human health and/or the environment. Risk Assessors seek to determine a safe level for each contaminant present. A risk assessment may propose alternative cleanup target levels for groundwater or soil. A risk assessment may utilize fate and transport models to document that human health and environmental risks are acceptable, and to document that potential risks associated with the establishment of alternative CTLs are acceptable. A risk assessment may employ probabilistic risk assessment methods to document that human health and environmental risks are acceptable on the site.
Remedial Action Plan (RAP) – Required by DEP when active remediation is required.
Any active remediation should include a RAP. The objective of active remediation shall be to meet the applicable No Further Action criteria of Rule 62-780.680, F.A.C., or the Natural Attenuation with Monitoring criteria of Rule 62-780.690, F.A.C. The plan provides a design that addresses cleanup of all contaminated soil, sediment, groundwater, or surface water on a site, and should also address contamination that has migrated into any medium beyond the boundary of the source property. See 62-780.700, F.A.C. for plan components.
Performance Monitoring/Operation & Maintenance/Injection Monitoring/Status Reports – Required by DEP when active remediation is approved.
Performance Monitoring Reports may have many names but are turned in for review to DEP during active remediation to determine stability of the contamination plume and/or performance of the remediation treatment used. This step is required prior to the recommendation for no further action.
Pilot Study Work Plan (PSWP) - Site-specific step.
A preliminary study can be conducted to evaluate the feasibility, effectiveness, and potential environmental impact of a proposed remediation method for contaminated sites. Before performing a pilot test, the Person Responsible for Site Rehabilitation (PRSR) must submit a PSWP to DEP for review. This plan ensures compliance with applicable requirements, such as permits or authorizations (for example underground injection control, National Pollutant Discharge Elimination System or air emissions), and verifies that human health and the environment are adequately protected. See 62-780.700(2), F.A.C.
Pilot Test Report - Site-specific step.
Summarizes the findings and results of the pilot test conducted as part of the remediation process. If the pilot test is part of a Remedial Action Plan, the results would be incorporated into the plan to justify the selected remediation method and demonstrate its feasibility. DEP may require additional information or modifications based on the findings of the pilot test.
Source Removal Report (SRR) - Site-specific step.
During remedial action, a SRR is a document submitted by the PRSR to the DEP after completing source removal activities. It provides detailed information about the removal process and its outcomes. The content of the report is similar to requirements in 62-780.500(7), F.A.C.
Soil Management Plan (SMP) - Site-specific step.
Typically outline procedures for handling, treating, and disposing of contaminated soil during site rehabilitation activities. See Soil Management Plan guidance.
Groundwater Monitoring Plan (GMP) - Site-specific step.
If groundwater contamination is present, sampling and analyses from a number of representative monitoring wells should be conducted to verify the horizontal and vertical extent of the plume. An initial design for monitoring during remediation should be proposed in the RAP – it can be modified as conditions change.
Natural Attenuation with Monitoring (NAM) Plan – Site specific step (as applicable).
Note: May be included within a Site Assessment Report or Risk Assessment Report.
See 62-780.690 F.A.C.
Natural Attenuation Monitoring and long-term natural attenuation monitoring are allowable strategies for site rehabilitation depending on the individual site characteristics, provided human health, public safety, and the environment are protected. For some sites a path of long-term monitoring is appropriate to reach an end point of stability or diminishing concentrations. If the criteria of subsection 62-780.690(1), F.A.C., are met, a Natural Attenuation with Monitoring Plan, prepared pursuant to subsection 62-780.690(8), F.A.C., may be submitted.
Post Active Remediation Monitoring (PARM) Plan – Site specific step (as applicable).
See 62-780.750, F.A.C.
Post active remediation groundwater monitoring shall be performed following the completion of active groundwater remediation or soil remediation as described in rule 62-780.700, F.A.C., unless DEP has concurred that groundwater sampling is unnecessary based on the site-specific conditions or the site rehabilitation is continuing under Natural Attenuation Monitoring pursuant to rule 62-780.690, F.A.C. If active remediation is restarted, PARM will need to start over after the active remediation is completed. Only sampling results collected after remedial actions are considered complete will be accepted for the plume stability evaluation.
No Further Action Proposal (NFAP) – Included within a Site Assessment Report, Risk Assessment Report or Site Rehabilitation Completion Report.
A NFAP is provided when the criteria for No Further Action have been met. The No Further Action Proposal shall include comprehensive tables required pursuant to subparagraph 62-780.600(8)(a)27., F.A.C., updated as applicable. Prior to approval of a NFAP with an institutional control or an engineering control accompanied by an institutional control, documentation of completion of notification pursuant to subsection 62-780.220(7), F.A.C., shall be submitted to DEP. It is also recommended that Institutional Control Procedure Guidance (ICPG) Attachment 5 be used to prepare the NFAP.
Site Rehabilitation Completion Report (SRCR) – Required for DEP under 62-780, F.A.C. when NAM or PARM are considered complete.
A SRCR with a NFAP is submitted either when PARM is considered complete pursuant to paragraph 62-780.750(4)(f), F.A.C. or when NAM is considered complete pursuant to paragraph 62-780.690(8)(g), F.A.C. (considering specified time frames). The Site Rehabilitation Completion Report shall include the documentation required in either paragraph 62-780.750(4)(d), F.A.C., for the PARM or in paragraph 62-780.690(8)(d), F.A.C. for NAM to support the opinion that site cleanup objectives have been achieved. It is also recommended that Institutional Control Procedure Guidance (ICPG) Attachment 5 be used to prepare the SRCR.
Engineering Control Maintenance Plan (ECMP) - Required for DEP if site needs engineering control for closure.
The engineering control process is a four-step process.
- Step 1 – DEP approval of the proposed engineering controls.
- Step 2 - At the time when the construction of the engineering control(s) is completed, a Professional Engineer Certification Statement (in accordance with ICPG Attachment 31, should be submitted for approval by DEP). This statement must document that to the best of the Professional Engineer’s knowledge, the engineering control(s) for this site are consistent with commonly accepted engineering practices, are appropriately designed for their intended purpose, and have been constructed. This certification must be supported by detailed site information and other considerations that led the Professional Engineer to certify the engineering control(s) as competent for the life of the control if maintenance is provided. Note: this is a separate certification statement from Section 471, Florida Statutes (F.S.)/Rule 62-780.400, F.A.C., professional statement.
- Step 3 - ECMP will need to be prepared and submitted to DEP for review. The ECMP must contain the plan elements as specified in the ICPG Attachment 31. The ECMP does not require a Professional Engineer’s Certification Statement. It does need to identify each engineering control, type of maintenance anticipated, and a checklist to be used during the specified inspection frequency.
- Step 4 - The engineering control will also need to be included as a restriction in a Declaration of Restrictive Covenant (DRC) and the Institutional Controls Registry (ICR) and a GIS shapefile will need to be submitted in accordance with ICPG Section D. The shape files associated with the designated engineering controls will need to be submitted to the ICR web address. The Registry web address is https://floridadep.gov/waste/waste/content/institutional-controls-registry.
Institutional Control Package – When institutional controls or engineering controls are needed for closure.
An institutional control package (DRCs and/or Non-Recorded Institutional Controls) is documentation gathered for the current common practice for closure of contaminated sites with conditions. DEP provides guidance for parties considering pursuing such closures. If institutional or engineering controls are necessary to restrict exposure to groundwater or soil remaining on the site after closure, those controls will need to be registered in the Institutional Controls Registry (ICR) and a GIS shapefile will need to be submitted in accordance with ICPG Section D.
.
