All contaminated media removed from a site including water, soil and product must be properly disposed. Legible copies of manifests confirming their ultimate disposition should be provided as part of the Purchase Order deliverable. While the requirements for disposal of contaminated media removed as part of active cleanup are addressed in the approved Remedial Action Plan, a frequent concern is what to do with development water, purge water, and drill cuttings collectively referred to as “Investigation-Derived Waste” or IDW. When required, disposal of IDW is usually performed by a subcontractor, although the representative of the Contractor must be on-site to sign the disposal manifest.
If any contaminated media, including IDW, is disposed of outside the source property, then copies of the disposal manifest(s) documenting proper disposal must be provided as part of the deliverable for that task. If the method of disposal is thermal treatment, then the documentation should also include a copy of the certificate of destruction. For PRP funded sites, for each IDW disposal event, a one‑person mobilization plus the subcontractor’s charge are allowed. No additional time is allowed for the Contractor to oversee the loading of the drums by the disposal subcontractor. This is because the time to load the drums is generally minimal and the purpose of the Contractor being on-site is to point out the location of the drums to the disposal subcontractor and to sign the manifest. When possible, collection of the disposal soil samples should be combined with another activity, such as well installation if IDW will be generated.
Soil (Petroleum Contaminated and Clean)
In the past, soil IDW was drummed during well installation activities if there was no place to spread it on the source property or if it was “excessively” contaminated. The adoption of analytical soil cleanup target levels makes spreading the soil based solely on Organic Vapor Analyzer (OVA) screening results inappropriate, unless the soil is spread on an unpaved area known to be significantly contaminated at the surface or if there have been sufficient analytical results obtained from the various source areas that allow the use of OVA screening results to determine if it is appropriate to spread the soil anywhere on the source property.
During well installation, if the volume of soil is significant, the Contractor should make the effort to segregate soil derived from source areas suspected to be contaminated (soil that yields OVA readings above background, typically >10 part per million [ppm]) from potentially uncontaminated soil derived from perimeter areas (soil that yields OVA readings below background, typically <10 ppm). If practical, the Contractor also should try to separate contaminated soil in source areas with evidence of free product or staining with very high OVA readings.
If the contaminated soil is going to be thermally treated, then a characterization of the waste must be performed in accordance with pretreatment requirements of Chapter 62‑713, F.A.C., to show that the soil is nonhazardous. This characterization is accomplished by collecting pre-burn soil sample(s) during the drilling event and analyzing the sample(s) for Volatile Organic Halocarbons (discrete), Total Recoverable Petroleum Hydrocarbons (TRPHs), Arsenic, Cadmium, Chromium and Lead (composite). If the soil will be taken out of state, it may be necessary to include Volatile Organic Aromatics, Polycyclic Aromatic Hydrocarbons, and the four remaining Resource Conservation and Recovery Act of 1976 (RCRA) metals in the analyses. Some Florida counties or municipalities may have additional requirements. On the other hand, pretreatment facilities have the discretion of utilizing assessment data (TRPHs, for example) in lieu of separate analyses. Any time there is deviation from the requirements of Chapter 62‑713, F.A.C., the Contractor needs to justify the reason for the deviation. However, soil can be disposed as clean fill if it meets both the direct exposure residential soil cleanup target levels and the leachability soil cleanup target levels based on groundwater criteria of contaminants of concern pursuant to Table II of Chapter 62‑777, F.A.C.
DEP has concerns with disposition of “Clean” soil generated during site rehabilitation activities outside of the source property. The first issue is that the sampling and testing protocols for determining whether soil is clean cannot be guaranteed to be 100 percent representative or to ensure that no residual petroleum odors persist. The second issue is that there may be other non-petroleum contaminants present in the soil that are not included in the analytical screening. Necessary and reasonable costs to comply with this provision including transportation to the landfill, clean soil tipping fees, and/or supplemental analytical testing required by the landfill are authorized.
The preferred option is to return all clean soil to the excavation or otherwise spread it on the source property. However, if clean soil needs to be removed from the source property it should be sent to a permitted landfill as “clean overburden.” Alternative options for use in an industrial setting may be considered on a case-by-case basis. At NO TIME shall clean soil be disposed in or near a residential area or an area that is likely to be used for residential purposes in the future.
Petroleum Contaminated Purge Water and Development Water
Currently, there are no requirements by DEP for treating well purge water or development water IDW. Typically, the water extracted from a well may be discharged onto a paved area and allowed to evaporate if it is not mixed with free product and will not affect uncontaminated areas or flow beyond the source property boundaries or into a storm water drain. It may be necessary to drum the development water if the volume of water is large, such as during well development activities, or if the groundwater is anticipated to be highly contaminated and/or mixed with free product. If the water is drummed, it must be transported from the source property by a disposal subcontractor or treated at the source property utilizing a portable treatment system. Contractors should coordinate with the site owner prior to discharging large volumes of water at the source property.
The Florida Department of Environmental Protection is the state’s lead agency for environmental management and stewardship – protecting our air, water and land. The vision of the Florida Department of Environmental Protection is to create strong community partnerships, safeguard Florida’s natural resources and enhance its ecosystems.