Performance Based Cleanups Performance Based Cleanups Florida Department of Environmental Protection Florida Department of Environmental Protection Bureau of Petroleum Storage Systems Bureau of Petroleum Storage Systems Ferda Yilmaz Ferda Yilmaz The 17th Annual UST/LUST National Conference March 2005
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Performance Based CleanupsPerformance Based CleanupsFlorida Department of Environmental ProtectionFlorida Department of Environmental Protection
Bureau of Petroleum Storage SystemsBureau of Petroleum Storage Systems
Ferda YilmazFerda Yilmaz
The 17th Annual UST/LUST National Conference March 2005
• Streamlined Site Assessment (StSA)
• Streamlined Remediation– Performance Based Cleanups (PBCs)
Streamlined ProcessesStreamlined Processes
• Streamlined Site Assessment (StSA)
• Streamlined Remediation– Performance Based Cleanups (PBCs)
Total Number of Agreements 356Total Value $70,000 KAvg. Cleanup Cost Tier-1 $355 KAvg. Cleanup Cost Tier-2 $215 KSite Closures 57Time to Closure 2-6 yrs
PBC OverviewPBC Overview
Total Number of Agreements 356Total Value $70,000 KAvg. Cleanup Cost Tier-1 $355 KAvg. Cleanup Cost Tier-2 $215 KSite Closures 57Time to Closure 2-6 yrs
• What is PBC?
• How do we price PBCs?
• How do we negotiate PBCs?
• How do we finalize PBCs?
Performance Based Cleanups (PBCs)Performance Based Cleanups (PBCs)• What is PBC?
– How do we get there?– What are the proposal requirements?
• Baseline Sampling• Remedial Action Plan• Remedial Action Implementation• Operation & Maintenance (O&M)• Post Remedial Monitoring (PRM)• Site Closure
Basic Proposal Elements
PBC Proposal PBC Proposal
• Baseline Sampling• Remedial Action Plan• Remedial Action Implementation• Operation & Maintenance (O&M)• Post Remedial Monitoring (PRM)• Site Closure
Basic Proposal Elements
• Baseline Sampling
– Required if Data > 9 months old
– Include Key & Perimeter wells
– Include all contaminants
PBC Proposal ElementsPBC Proposal Elements
• Baseline Sampling
– Required if Data > 9 months old
– Include Key & Perimeter wells
– Include all contaminants
• Remedial Action Plan
– May be included in PBC
– Pilot test is optional
– Consider level of effort for design
– FDEP review requirements different
PBC Proposal ElementsPBC Proposal Elements
• Remedial Action Plan
– May be included in PBC
– Pilot test is optional
– Consider level of effort for design
– FDEP review requirements different
•Trailer unit •Fenced treatment compound
•Trenching length•Materials
•Number of people •Number of days
• Remedial Action Plan Implementation
– Equipment:
– Construction:
– Labor:
PBC Proposal ElementsPBC Proposal Elements
• Remedial Action Plan Implementation
– Equipment:
– Construction:
– Labor:
•Trailer unit •Fenced treatment compound
•Trenching length•Materials
•Number of people •Number of days
• Operation & Maintenance– Number of years in O&M
– Key & Perimeter well sampling plan– Reporting frequency
– Utilities– Permits– Repairs
PBC Proposal ElementsPBC Proposal Elements
• Operation & Maintenance– Number of years in O&M
– Key & Perimeter well sampling plan– Reporting frequency
– Utilities– Permits– Repairs
• Post Remedial Monitoring
– Key & perimeter well sampling plan
– Reporting frequency
– Consider rebounds
PBC Proposal ElementsPBC Proposal Elements
• Post Remedial Monitoring
– Key & perimeter well sampling plan
– Reporting frequency
– Consider rebounds
• Site Closure
– Well abandonment
– Equipment demobilization
PBC Proposal ElementsPBC Proposal Elements
• Site Closure
– Well abandonment
– Equipment demobilization
Pricing & Negotiation TeamPricing & Negotiation Team
Distribution
Team Member A Team Member B Team Member C
Key & Perimeter Wells Sampling Parameters Sampling Frequency Cleanup Time Reporting Frequency
Cost Estimate Range
Exchange Comments
Teleconference/Meeting
15 Days Review Time
Proposal Received
• By e-mail• Copy e-mail to team members• Lay out changes
• Number of key & perimeter wells• Sampling frequency• Sampling parameters• Reporting frequency
Negotiation TeamNegotiation Team
• By e-mail• Copy e-mail to team members• Lay out changes
• Number of key & perimeter wells• Sampling frequency• Sampling parameters• Reporting frequency
PBC Template
Target Levels: Groundwater GCTLs pursuant to 62-770Soil SCTLs pursuant to 62-770Free Product Free Product shall not be present Surface Water No Surface Water Body Affected by ContaminationOther N/A
Key Wells (list): MW-1, MW-7, MW-8, DMW-1
Sampling Frequency (in RA): Quarterly Parameters: BTEX + MTBE by EPA 8021
Perimeter Wells (list): MW-3, MW-4, MW-10, MW-12 Sampling Frequency (in RA): Quarterly
Target Levels: Groundwater GCTLs pursuant to 62-770Soil SCTLs pursuant to 62-770Free Product Free Product shall not be present Surface Water No Surface Water Body Affected by ContaminationOther N/A
Key Wells (list): MW-1, MW-7, MW-8, DMW-1 Sampling Frequency (in RA): Quarterly