HomeMy WebLinkAboutExhibit 4 - Version ASupplemental Documents Submitted by Applicant
THE GOLDSTEIN ENVIRONMENTAL LAW FIRM, P.A.
Transactions, Due Diligence, Development, Brown, fields, Cleanups e.7 Compliance
One Southeast Third Avenue, Suite 2120
Miami, Ronda 33131
Telephone: (305) 777-1680
Facsimile: (305) 777-1681
www.goldsteinenvlaw.com
Michael R. Goldstein, Esq.
Direct Dial: (305) 777-1682
Email: mgoldstein@goldsteinenvlaw.com
February 22, 2013
Via Email & U.S. Mail
Ms. Alice Bravo, Interim City Manager
City of Miami
3500 Pan American Drive
Miami, FL 33131
Re: Response to Request for Supplemental Information in Connection with
Pending Brownfield Area Designation Requests
West Brickell View Apartments, 144 and 152 SW 86 Street
Vista Grande Apartments, 850 SW 2nd Avenue; and
West Brickell Tower Apartments, 1026 SW 2nd Avenue
Dear Ms. Bravo:
The purpose of this correspondence is to respond to your request for additional information
regarding the environmental conditions associated with the pending brownfield area designation
requests for the three above -referenced projects and the burdens, risks, and other complexities they
have imposed on the developer.
1. We start first with the definition of a "brownfield site" under Florida Statutes.' Florida
Statutes section 376.79(3) defines a brownfield site to mean real property, the expansion,
redevelopment, or reuse of which may be complicated by actual or perceived environmental
contamination. Taken piece -by -piece, the key elements of the definition of a brownfield site are
therefore as follows:
• real property;
• actual or perceived contamination;
I See Exhibit A.
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Ms. Alice Bravo
February 22, 2013
Page 2
• expansion, redevelopment or reuse of real property;
• the complication of expansion, redevelopment or reuse of real property; and
• the complication of expansion, redevelopment or reuse of real property by actual or
perceived contamination.
2. Note that the statute, unfortunately, doesn't define the term "complicate."' It also doesn't
define what is meant by "perceived contamination."' "Actual contamination," however, speaks for
itself and can be readily demonstrated through the results of laboratory analysis of soil and
groundwater.
3. It is noteworthy that nothing in the definition of the term "brownfield site" - or in any other
provision of Florida Statutes - requires actual or perceived environmental contamination to be
documented al the property that itself is the subject of the brownfield area designation request. The
actual or perceived contamination may, and frequently is, located adjacent or close to the site sought
to be designated. In other words, so long as the actual or perceived contamination can be
demonstrated to exist and can be further demonstrated to complicate expansion, redevelopment, or
reuse of the property sought to be designated, the property sought to be designated in fact falls
within the scope of the definition of "brownfield site."
4. As we describe in the following paragraphs, actual contamination has complicated
expansion, redevelopment and reuse at all three sites where the developer is seeking the brownfield
area designation.
5. The actual contamination at issue arises out of, and has been most clearly and extensively
documented at, two separate gas station sites that are adjacent and/or in sufficient proximity to the
three referenced development sites. The first such gas station site is the Citgo fueling station located
at 190 SW 8th Street, which directly adjoins the West Brickell View Apartments development site to
the west and is located a mere 75 feet or so from the Vista Grande Apartments development site
across SW 2nd Avenue to the east. The second such gas station site is the BP/Brickell Trading Post,
2 In the almost sixteen years since passage of the Florida Brownfields Redevelopment Act, the term "complicate" has
widely and commonly been used to described any material design, permitting, regulatory liability, third party liability,
cleanup liability, additional cost, and/or construction schedule delay related burdens that a developer is forced to bear as
a result of the presence or perceived presence of contamination issues at or in proximity to the development site. And it
is precisely these very burdens and issues that create the policy justification for brownfield incentives in the first instance.
Environmental driven complexities put these reuse projects involving brownfield sites at a competitive disadvantage
relative to clean sites, which, in turn creates market dysfunction and unsustainable and disconnected growth patterns.
Without equalizers in the form of financial and regulatory incentives, developers would not be able to accommodate the
extra costs, schedule delays, design modifications, and liability risks that are always, in one combination or the other,
attendant to actual or perceived contamination.
3 In each of the original brownfield designation requests, all filed with the City of Miami on December 28, 2012, we also
discuss several instance of "perceived contamination"; however, we only discuss the several incidents of actual
contamination in this supplemental response because (i) they are so objectively demonstrated and (ii) the development
complications they create for, and impose on, each of the three referenced projects are so obvious and irrefutable.
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Ms. Alice Bravo
February 22, 2013
Page 3
located at 1245 SW 2nd Avenue, which is within approximately 400 feet of the West Brickell Tower
Apartments development site to the south.
Actual Contamination at Citgo Site and the Expansion, Redevelopment or Reuse
Complication for West Brickell View Apartments and Vista Grande Apartments
6. The Miami -Dade County Department of Regulatory and Economic Resources ("RER")
maintains electronic and physical records for the Citgo site under the file numbers UT-439/F-7173.
See Exhibit B.
7. As reflected by the records enclosed at Exhibit Bs the Citgo site was reported to contain
three 10,000 gallon gasoline underground storage tanks ("USTs") and one 1,000 gallon waste oil
UST. In June of 1987 and April of 1993, the owner reported significant discharges of petroleum
related products; however, due to the financial status of the responsible party and funding
limitations at the state level, no meaningful investigation of the extent of contamination or off -site
migration has ever been performed.
8. On September 4. 2012, the developer's environmental consultant, Dunkelberger Engineering
& Testing, Inc. ("Dunkelberger"),4 concluded an exhaustive investigation of the Citgo site as well as
other incidents of actual contamination complicating development for the West Brickell View
Apartments site and, in a Phase I Environmental Site Assessment ("ESA") Update, reported the
following material findings (among others):
• "A Citgo gasoline service station, which has had two documented petroleum discharges,
exists on the adjacent property to the west. Given that the subject site is located hydraulically
downgradient of the Citgo Station with respect to the regional groundwater flow direction,
and the lateral extent of the groundwater hydrocarbon plume has not been assessed for over
20 years, the potential for the hydrocarbon plume to have migrated underneath the site
cannot be ruled out. Further, the facility has performed automodve service (including the
operation of a waste oil underground storage tank) immediately adjacent to the site for over
35 years, which may have resulted in localized contamination impacts."
• "Review of historical sources shows that a gasoline service station operated at the property
just northwest of the site (currently a Wells Fargo Bank) from the mid 1920s through the
early 1970s. Petroleum contaminated soils were found along the north side of the S.W. 8''
Street right-of-way (i.e., just south of the bank property) during the installation of the
stormwater drainage utilities in 1985 which suggests that the former gasoline service station
had a past petroleum discharge(s). Given the proximity of this former gasoline service
station to the site and the fact that the subject site is located hydraulically downgradient of
4 The Florida Licensed Environmental Professional who signed and certified all of the Dunkelberger reports discussed in
this correspondence is Thomas Tepper, a Professional Engineer with over 40 years of experience in environmental and
geotechnical consulting, including more than 30 years in South Florida alone.
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Ms. Alice Bravo
February 22, 2013
Page 4
the former gasoline service station, the potential exists for hydrocarbon impacted
groundwater to have migrated underneath the site."
9. Ultimately, the developer was forced to incur the cost and bear the delay of investigating
these various environmental issues through a Phase II ESA environmental investigation of soil and
groundwater, which was conducted in July and August of 2011 by Dunkelberger. While, the Phase
II did not document any on -site contamination, it did reveal another important issue of concern
related to actual contamination that further complicated development by requiring design
modifications and adding yet more cost and delay to the project. As stated by Dunkelberger in its
September 4, 2012 Phase I ESA Update:
". . . the existing groundwater contamination at the aforementioned facilities and others
nearby could present a concern should dewatering be require in connection with re-
development of the subject property for residential purposes. Specifically, the potential
exists for contaminated groundwater to migrate from the facilities towards the site since
dewatering activities would cause water table lowering that leads to contaminant plume
movement. Thus, the presence of ground water contamination would place some degree of
restriction on construction dewatering, if required. Dewatering activities may require special
evaluation as part of dewatering permitting through the South Florida Water Management
District (SFWM.D) and the Miami -Dade County DepaiLulent of Environmental Resources
Management (DERM) with technical based assurances provided that the pre -drainage
activities would not cause contaminated groundwater to migrate. Utilization of special
construction techniques could be necessary to assure that contaminant plume movement
does not occur."
10. This concern about the additional design modification and increased engineering and
development costs were, in fact, realized in connection with West Brickell View Apaii.uients when in
correspondence from Miami -Dade County RER, to the developer's engineering consultant, dated
August 21, 2012 (see Exhibit C), the developer was ordered to make extensive showings that its
proposed drainage plans would not impact on, or make worse, the actual contamination at the
adjacent Citgo property. RER ultimately approved the drainage plans but the developer was
cautioned as follows: `Be advised that in the event that evidence of ground and/or ground water
contamination is encountered, the responsible party or his designee is required to immediately notify
[RER].... Furthermore, based on findings, modifications to the drainage plan may be necessary."
Accordingly, the presence of actual contamination in groundwater at the Citgo site created
significant site design and development complexity to prepare and implement drainage plans
consistent with RER's directives, including but not limited to changes in site plans, the preparation
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Ms. Alice Bravo
February 22, 2013
Page 5
of alternative drainage plans, the incurrence of additional consulting costs for Phase II testing, and
the incurrence of additional environmental legal costs for liability and regulatory analysis.5
11. As an additional burden and level of complexity, the environmental legal risk associated with
the actual contamination at the Citgo site is particularly troubling, complex, and far-reaching to the
developer due to the fact that any exacerbation (i.e., spreading) of off -site groundwater
contamination during construction6 would operate to expose the developer to cleanup liability to
RER, the Florida Department of Environmental Protection ("FDEP"), and, potentially, the owner
of the Citgo station. Obviously, the developer would not be faced with any of these legal liability
risks — or the corresponding costs associated with environmental consultants and legal counsel to
help limit and manage the risk - in the absence of contamination at the Citgo station; i.e., if it had
chosen to develop a greenfield site. The fact of the matter, however, is that these are real and major
complexities arising out of actual contamination that severely complicates redevelopment and reuse
of real property, specifically the West Brickell View and Vista Grande Apartment projects.
12. In addition to all of the soil and groundwater redevelopment and reuse complexities
discussed in the previous paragraphs, there is yet another form or material complexity related to the
Citgo station as it applies to the West Brickell Tower Apartments and Vista Grande Apartments
projects. Specifically, we have enclosed a document at Exhibit D drafted by the FDEP that speaks
to the health risks associated with building on or near contaminated sites like the Citgo gas station,
"Petroleum Product Indoor Vapor Intrusion Guidelines (Interim) (the "Interim Vapor Intrusion
Guidelines"). In material part, the Interim Vapor Intrusion Guidelines state:
"Draft EPA guidance and other available literature on vapor intrusion evaluation suggests
that there is a real possibility of indoor vapor intrusion occurring at buildings both on a
contaminated site and buildings adjacent to or in close proximity to a contaminated site;
however, it appears that the frequency of occurrence of problems of petroleum vapors
entering off -site buildings through the building foundation is relatively low. The science
related to vapor intrusion evaluation is still evolving and there will be a need for the
petroleum cleanup program to refine the procedures for vapor intrusion evaluation in the
5 These concerns and complexities applied equally to Vista Grande Apartments where Dunkelberger stated in its Phase I
ESA Update for that project, "While the contamination [from the Citgo] has not migrated to the subject property, the
existing groundwater contamination could present a concern to the site should dewatering be require in connection with
residential re -development. Specifically, the potential exists for contaminated groundwater to migrate from the facilities
towards the site since dewatering activities would cause water table lowering that leads to contaminant plume movement.
Thus, the presence of ground water contamination would place some degree of restriction on construction dewatering, if
required. Dewatering activities may require special evaluation as part of dewatering permitting through the South
Florida Water Management District (SFWMD) and the Miami -Dade County Department of Environmental Resources
Management (DERM) with technical based assurances provided that the pre -drainage activities would not cause
contaminated groundwater to migrate. Utilization of special construction techniques could be necessary to assure that
contaminant plume movement does not occur."
6 As noted by Dunkelberger, such exacerbation or spreading could be easily caused by construction dewatering, which, if
not designed and conducted properly, will pull a contaminant plume from a source property onto a development sites by
drawing down on the aquifer.
{00004026.DOCX. 1 }
Ms. Alice Bravo
February 22, 2013
Page 6
future when greater knowledge about this pathway is available; however the available
information at this time on this subject indicates that it is prudent for the Bureau of
Petroleum Storage Systems to establish interim procedures for evaluation of the potential for
indoor vapor intrusion and identify measures of mitigation."
(emphasis added)
13. This risk of possible vapor intrusion as it relates to the Citgo site, where actual
contamination has been documented and impacts on both West Brickell View and Vista Grande
Apartments, is an obvious, additional, material complication that further affects expansion,
redevelopment, and reuse by imposing design burdens, schedule delay, liability risk, and additional
costs for environmental consultants and counsel to interpret and apply the guidelines. Moreover,
the guidelines make clear that risk does not necessarily go away with time given that "the science
related to vapor intrusion evaluation is still evolving" and that "there will be a need for the
petroleum cleanup program to refine the procedures for vapor intrusion evaluation in the future
when greater knowledge about this pathway is available." In other words, the developer will be
living with this issue, and the regulatory and liability burdens associated with, far into the future until
and unless the underlying contamination at the Citgo site is remediated.
Actual Contamination at BP/Trading Post Site and the Expansion, Redevelopment or
Reuse Complication for West Brickell Tower Apartments
14. RER maintains electronic and physical records for the BP/Brickell Trading Post site
(formerly referred to as the Ramirez 66 Service Station) under the file numbers UT-528/F-7243.
See Exhibit E.
15. As reflected by the records enclosed at Exhibit E, the BP/Brickell Trading Post site, which
is within 400 feet of West Brickell Tower Apartments, was reported to contain up to 8 USTs,
including one 1,000 gallon UST for waste oil, one 1,000 gallon UST for kerosene, two 2,000 gallon
USTs for gasoline, two 4,000 gallon USTs for gasoline, and two 12,000 gallon USTs for gasoline. In
July of 1988 and November of 1992, significant discharges of petroleum related products were
reported to the FDEP; however, due to the financial status of the responsible party and funding
limitations at the state level, no meaningful investigation of the extent of contamination or off -site
migration has ever been performed and the commencement of cleanup is not anticipated to occur at
anv time in the foreseeable future. In the meantime, contamination in the subsurface continues to
spread unabated.
16. The regulatory and liability concerns and corresponding development complexities discussed
above with respect to groundwater contamination as they relate to actual contamination and the
West Brickell View and Vista Grande Apartment projects are equally relevant and burdensome to
the developer here. As evidence of such development complexity and the costs that have been
incurred to work through the development complexity, the developer's environmental consultant,
(00004026.0OCX. 1 )
Ms, Alice Bravo
February 22, 2013
Page 7
Dunkelberger Engineering & Testing, Inc., concluded in its Phase 1 ESA for the subject property,
dated September 4, 2012 as follows:
".....several properties in the site vicinity are listed on multiple environmental databases.
Contamination which exists at some of these facilities does not appear to have migrated to
the subject property given their geographic separation and location from the site with respect
to the regional groundwater flow... . However, the groundwater contamination could
present a concern to the site should dewatering be required in connection residential re-
development. . • . Thus, the presence of ground water contamination would place some
degree of restriction on construction dewatering, if required.' Dewatering activities may
require special evaluation as part of dewatering permitting through the South Florida Water
Management District (SFWMD) and the Miami -Dade County Department of
Environmental Resources Management (DERI\ei) with technical based assurances provided
that the pre -drainage activities would not cause contaminated groundwater to migrate.
Utilization of special construction techniques could be necessary to assure that contaminant
plume movement does not occur."
17, Exacerbation of any of the above -described contaminant plumes by the developer of West
Brickell View Tower exposes the developer to regulatory and legal liability risk to RER, FDEP, and
private third -parties. This liability risk is a direct result of the subject property's proximity to the
various sources of actual contamination and burdens and complicates reuse and redevelopment by
forcing the developer to incur additional expenses, design modifications, contingency planning and
schedule delays to modify and carefully manage site development and construction activities.
Based on all the foregoing empirical evidence, including regulatory correspondence, the opinions of
a Florida licensed environmental professional, and the undersigned's legal opinion (premised on
twenty-one years of experience with assisting private and public clients manage environmental,
construction, legal, regulatory, and/or financing risks at contaminated redevelopment sites), all three
referenced projects clearly fall within the definition of a "brownfield site" pursuant to section
7 There is no hard and fast rule established by RER as to when and how much proximity to a contaminated site triggers
a requirement to prepare and implement special dewatering measures to prevent plume exacerbation. Accordingly,
developers and environmental professionals look to other regulatory and industry standards, including many tunes to the
standard operating procedure ("SOP") adopted by the Broward County Environmental Protection and Growth
Management Department ("EPGMD"), for guidance. EPG v D's SOP, which can be found at Exhibit F, requires a
notice and pre -approval anytime dewatering is to occur "within a one -quarter mile radius of a contaminated site." Were
that standard formally in effect here, both the Citgo and the BP/Brickell Trading Post sites would fall within the one -
quarter radius and require with the SOP, including submittal of justification for the need for dewatering, water treatment
and disposal plans, a discussion of the effect of the dewatering and disposal procedures on the contaminant plume, and a
monitoring program. Even a cursory review of the SOP enclosed at Exhibit F reflects the detailed analysis and
modeling and extensive technical showings that are required by a regulatory agency to demonstrate that dewatering
activities will not spread existing contamination. It is this level of development complexity that the developer has had to
evaluate, work through, and ultimately overcome at each of the three development projects due to their respective
proximity to known contamination plumes.
100004026.DOCX.1 }
Ms. Alice Bravo
February 22, 2013
Page 8
376.79(3), Florida Statutes. For a demonstration of compliance with the underlying designation
criteria set forth at 376.80(2)(b), Florida Statutes, that apply to brownfield sites, please see the
individual designation requests filed separately for each project under separate cover on December
28, 2012.
We appreciate the opportunity to provide this additional information and remain available to
respond further as you may deem appropriate.
Thank you.
Very truly yours,
THE GOLDSTEIN ENVIRONMENTAL LAW FIRM, P.A.
Michael R. Goldstein
/g
Encl.
cc: West Brickell View Apartmments, Ltd.
Vista Grande Apartments, Ltd.
West Brickell Tower Apartments, Ltd.
{00004026,DOCX. 1 }
Exhibit A
{00001271.D0CX. 1 }
Statutes & Constitution :View Statutes : Online Sunshine
Page 1 of 2
Select Year:
The 2011 Florida Statutes
2011
Go
Title XXVIII
NATURAL RESOURCES; CONSERVATION,
RECLAMATION, AND USE
Chapter 376 View Entire
POLLUTANT DISCHARGE Chapter
PREVENTION AND REMOVAL
376.79 Definitions relating to Brownfields Redevelopment Act. —As used in ss. 376.77.376.85, the
term:
(1) "Additive effects" means a scientific principle that the toxicity that occurs as a result of
exposure is the sum of the toxicities of the individual chemicals to which the individual is exposed.
(2) "Antagonistic effects" means a scientific principle that the toxicity that occurs as a result of
exposure is less than the sum of the toxicities of the individual chemicals to which the individual is
exposed.
(3) "Brownfield sites" means real property, the expansion, redevelopment, or reuse of which may be
complicated by actual or perceived environmental contamination.
(4) "Brownfield area" means a contiguous area of one or more brownfield sites, some of which may
not be contaminated, and which has been designated by a local government by resolution. Such areas
may include all or portions of community redevelopment areas, enterprise zones, empowerment zones,
other such designated economically deprived communities and areas, and Environmental Protection
Agency -designated brownfield pilot projects.
(5) "Contaminant" means any physical, chemical, biological, or radiological substance present in any
medium which may result in adverse effects to human health or the environment or which creates an
adverse nuisance, organoteptic, or aesthetic condition in groundwater.
(6) "Contaminated site" means any contiguous land, sediment, surface water, or groundwater areas
that contain contaminants that may be harmful to human health or the environment.
(7) "Department" means the Department of Environmental Protection.
(8) "Engineering controls" means modifications to a site to reduce or eliminate the potential for
exposure to chemicals of concern from petroleum products, drycleaning solvents, or other
contaminants. Such modifications may include, but are not limited to, physical or hydraulic control
measures, capping, point of use treatments, or slurry watts.
(9) "Environmental justice" means the fair treatment of all people of all races, cultures, and
incomes with respect to the development, implementation, and enforcement of environmental laws,
regulations, and policies.
(10) "institutional controls" means the restriction on use of or access to a site to eliminate or
minimize exposure to chemicals of concern from petroleum products, drycleaning solvents, or other
contaminants. Such restrictions may include, but are not limited to, deed restrictions, restrictive
covenants, or conservation easements.
(11) "Local pollution control program" means a local pollution control program that has received
delegated authority from the Department of Environmental Protection under ss. 376.80(9) and 403.182.
http://www.leg. state.fl.us/statutes/index.cfm?mode=View%20 S tatut es & SubMenu= 1 &App... 4/3 0/2012
Statutes & Constitution :View Statutes : Online Sunshine Page 2 of 2
(12) "Natural attenuation" means a verifiable approach to site rehabilitation that allows natural
processes to contain the spread of contamination and reduce the concentrations of contaminants in
contaminated groundwater and soil. Natural attenuation processes may include sorption,
biodegradation, chemical reactions with subsurface materials, diffusion, dispersion, and volatilization.
(13) "Person responsible for brownfield site rehabilitation" means the individual or entity that is
designated by the local government to enter into the brownfield site rehabilitation agreement with the
department or an approved local pollution control program and enters into an agreement with the local
government for redevelopment of the site.
(14) "Person" means any individual, partner, joint venture, or corporation; any group of the
foregoing, organized or united for a business purpose; or any governmental entity.
(15) "Risk reduction" means the lowering or elimination of the level of risk posed to human health or
the environment through interim remedial actions, remedial action, or institutional, and if appropriate,
engineering controls.
(16) "Secretary" means the secretary of the Department of Environmental Protection.
(17) "Site rehabilitation" means the assessment of site contamination and the remediation activities
that reduce the levels of contaminants at a site through accepted treatment methods to meet the
cleanup target levels established for that site. For purposes of sites subject to the Resource
Conservation and Recovery Act, as amended, the term includes removal, decontamination, and
corrective action of releases of hazardous substances.
(18) "Source removal" means the removal of free product, or the removal of contaminants from soil
or sediment that has been contaminated to the extent that leaching to groundwater or surface water
has occurred or is occurring.
(19) "Synergistic effects" means a scientific principle that the toxicity that occurs as a result of
exposure is more than the sum of the toxicities of the individual chemicals to which the individual is
exposed.
History.—s. 3, ch. 97-277; s. 2, ch. 98-75; s. 10, ch. 2000-317; s. 1, ch. 2004-40; s. 4, ch. 2008.239.
Copyright ®1995-2012 The Florida Legislature • Privacy Statement • Contact Us
http://www.leg.state.fl.us/statutes/index.cfrn?mode=View%20Statutes&SubMenu=1 &App... 4/30/2012
Exhibit B
{00001271.DOCX.1 }
Carlos Alvarez, Mayor
September 27, 2010
Jorge Braceras, Manager
Bricked Dominion, LLC.
1246 SW 15 St
Miami, FL 33145
Environmental Resources Management
Pollution Control Division
701 NW 1st Court • 4th Floor
Miami, Florida 33136-3912
T 305-372-6700 F 305-372-6982
CERTIFIED MAIL # 7007 2680 0000 0621 8931
RETURN RECEIPT REQUESTED--P-- -
Re: Limited Tank Closure Report Addendum dated August 19, 2010 and prepared by Jorge Braceras for the Ciao
Gas Station facility (UT-439/Fi1e-7173iDEP-8504877) feted at, near, or in the vcinity of 190 SW 8th St.,
Miami, Harm -Dade County, Florida.
Dear Mr. Braceras:
The Environmental Evaluation Sec#cn of the Department of Environmental Resources Management (DERM) has
reviewed the above referenced document received August 23, 2010 pertaining to the removal of three (3) 10,000
gallon Underground Storage Tank (UST) systems on October 28, 2010 and has determined that this report meets the
requirements of Rule 62-781.800, Florida Adrrdnisirative Code (FAC). Therefore, this report has been placed on fie
with other pertinent material regarding the subject site.
Contminaticn requiring further assessment is documented at the site from discharges dated June 18,1987, eligible
for the Early Detecon Incentive (EDI) program and for the April 30, 1993 discharge, eligible for the Petroleum
Liability and Restoration Insurance Program (PLIRP). However, in accordance with Florida Statute, F.S. 376.30, you
are required to obtain prior written approval from the Department for the scope of work and associated costs In order
to be pad from the Inland Protection Trust Fund for subsequent program tasks. Pre -approval requests for additional
work may be submited to the Department However, they will be reviewed based an priority score and availability of
funds. Voluntary work may continue to be performed at the site, as long as the work is performed in accordance with
Chapter 82-770, FAC.
If you have any questions concerning the above, please contact Eddie Gcnzaiez (gonzaed@niiamidade.gov) of the
Environmental Evaluation Section at (305) 372-6700.
Sincerely,
Wilbur Mayorga, P.E., Chief
Pollution Control Division
eg
FDEP file copy 138504677
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APPENDIX A
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Laboratory Analytical Reports
And
COMPOUND Chain of Custody Documentation
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TOTAL NAPHTHALENE CO TIONS (pg/L)
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TOTAL NAPHTIL1.II
PLUME MAP
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Environmental FirstSearch
Site Detail Report
Target Property: 1026 SW 2ND AVE
MIAMI, FL 33130
SEARCH ID: 34
DIST/DIR: 0.15 NE
JOB: FTL-11-0801
LUST
ELEVATION: 9
MAP ID: 5
NAME: CITGO STATION
ADDRESS: 190 SW 8TH ST
MIAMI FL 33130
MIAMI-DADE
CONTACT:
SOURCE FL DEP
REV: 7/18/12
)D1: 138504677
ED2: 8504677.00
STATUS: FACILITY OPEN
PHONE: (305) 856-4594
SITE INFORMATION
OPERATOR:JORGE BRACERAS
NAME UPDATED:05/17/2005
ADDR UPDATED:10/20/1999
BAD ADDR INDICATOR:N
RP ID:57000
RP ROLE:ACCOUNT OWNER
RP BEGIN:10/25/2004
NAME:G & B STANDARD INC
190 SW 8TH ST ATTN: JORGE BRACERAS
MIAMI FL 33130
PHONE:(305)856-4594
DISCHARGE INFORMATION
DISCHARGE DATE:04/30/1993
COMBINED:
SCORE:11
SCORE DATE:11/16/2007
CLEANUP REQUIRED:R - CLEANUP REQUIRED
WORK STATUS:INACTIVE
DISCHARGE CLEANUP STATUS:ENTD - ELIGIBLE - NO TASK LEVEL DATA
INFO SOURCE:D - DISCHARGE NOTIFICATION
OTHER SOURCE:
SITE MANAGER:
MANAGER END DATE:
TANK OFFICE: -
DISCHARGE DATE:06/18/1987
COMBINED:
SCORE:11
SCORE DATE:11/16/2007
CLEANUP REQUIRED:R -CLEANUP REQUIRED
WORK STATUS:INACTIVE
DISCHARGE CLEANUP STATUS:RA - RA ONGOING
INFO SOURCE:E- EDI
OTHER SOURCE:
SITE MANAGER:
MANAGER END DATE:
TANK OFFICE: -
APPLICATION RECD:6/22/1987
ELIGIBILITY STATUS:E
ELIGIBILITY DATE:12/13/1989
- Continued on next page -
Site Details Page - 4
Environmental FirstSearch
Site Detail Report
Target Property: 1026 SW 2ND AVE JOB: FTL-11-0801
MIAMI, FL 33130
LUST
SEARCH ID: 34
DIST/DIR: 0.15 NE ELEVATION: 9 MAP ID: 5
NAME CITGO STATION REV: 7/18/12
ADDRESS: 190 SW 8TH ST ID1: 138504677
MIAMI FL 33130 ID2: 8504677.00
MIAMI-DADE STATUS: FACILITY OPEN
CONTACT: PHONE: (305) 856-4594
SOURCE FL DEP
LETTER OF INTENT:06/22/1987
ELIG LETTER SENT:12/13/1989
REDETERMINED:N
INSPECTION DATE:05/13/1988
DEDUCTIBLE AMOUNT:
DED PAID TO DATE:0
CO PAY AMOUNT:
CO -PAID PAID TO DATE:0
CAP AMOUNT:
APPLICATION RECD:8/5/1993
ELIGIBILITY STATUS:E
ELIGIBILITY DATE:8/18/1993
LETTER OF INTENT:05/17/1993
ELIG LETTER SENT:08/18/1993
REDETERMINED:N
INSPECTION DATE:06/29/1993
DEDUCTIBLE AMOUNT:500
DED PAID TO DATE:1000
CO PAY AMOUNT:0
CO -PAID PAID TO DATE:0
CAP AMOUNT:1200000
UST INFORMATION
THIS SITE IS CURRENTLY REGULATED BY CHAPTER 62-761, F.A.C.
TOTAL NUMBER OF TANKS: 4
TANK INFORMATION
TANK ID:1STATUS:OPEN
TVI:TANKDEP CO:NO
INSTALLED:01-JAN-19825TAT DATE:
TK STAT:U - IN SERVICE
CAPACITY(GAL):9886
CONTENT:5 - UNLEADED GAS
PLACE:UNDERGROUND
TYPE:A - RETAIL STATION
TANK ID:2STATUS:OPEN
TVI:TANKDEP CO:NO
INSTALLED:01-JUL-1982STAT DATE:
TK STAT:U - IN SERVICE
CAPACITY(GAL):9886
CONTENT:B - UNLEADED GAS
- Continued on next page -
Site Details Page - 5
Environmental FirstSearch
Site Detail Report
Target Property: 1026 SW 2ND AVE
MIAMI, FL 33130
JOB: FTL-11-oso1
LU ST
SEARCH ID: 34
DIST/DIR: 0.15 NE
ELEVATION: 9
MAP ID: 5
NAME: CITGO STATION
ADDRESS: 190 SW 8TH ST
MIAMI FL 33130
MIAMI-DADE
CONTACT:
SOURCE FL DEP
REV: 7/18/12
ID1: 138504677
ID2: 8504677.00
STATUS: FACILITY OPEN
PHONE: (305) 856-4594
PLACE:UNDERGROUND
TYPE:A - RETAIL STATION
TANK ID:35TATUS:OPEN
TVI:TANKDEP CO:NO
INSTALLED:01-JUL-1982STAT DATE
TK STAT:U - IN SERVICE
CAPACITY(GAL):9886
CONTENT: B - UNLEADED GAS
PLACE:UNDERGROUND
TYPE:A - RETAIL STATION
TANK ID:45TATUS:OPEN
TVI:TANKDEP CO:NO
INSTALLED:01-JUL-1982STAT DATE:04-MAY-2011
TK STAT:B - REMOVED
CAPACITY(GAL):1011
CONTENT:L - WASTE OIL
PLACE:UNDERGROUND
TYPE:A - RETAIL STATION
1 E - FIBERGLASS
1M - SPILL CONTAINMENT BUCKET
1 N - FLOW SHUT-OFF
10 - TIGHT FILL
1 S - DEP APPROVED CONTAINMENT
2E - FIBERGLASS
2M - SPILL CONTAINMENT BUCKET
2N - FLOW SHUT-OFF
20 - TIGHT FILL
2S • DEP APPROVED CONTAINMENT
3E - FIBERGLASS
3M - SPILL CONTAINMENT BUCKET
3N - FLOW SHUT-OFF
30 - TIGHT FILL
35 - DEP APPROVED CONTAINMENT
PIPING INFORMATION
TANK ID:DESCRIPTION:
1 C - FIBERGLASS
1 F - DOUBLE WALL
1J - PRESSURIZED PIPING SYSTEM
1 K - DISPENSER LINERS
2C - FIBERGLASS
2F - DOUBLE WALL
2J - PRESSURIZED PIPING SYSTEM
2K - DISPENSER LINERS
- More Details Exist For This Site; Max Page Limit Reached -
Site Details Page 6
Exhibit C
{OCOO1271.DOCXe 1 }
Carlos A. Gimenez, Mayor
August 21,2012
Alberto A. Mora, P.E.
Schwebke — Shiskin & Associates, Inc.
3240 Corporate Way
Miramar, FL 33025
Department of Regulatory and Economic Resources
Environmental Resources Management
701 NW 1st Court, 4th Floor
Miami, Florida 33136-3912
T 305-372.6700 F 305-372-6982
CERTIFIED MAIL 7009 0080 0000 1045 7210
RETURN RECEIPT REQUESTED
miamidade.gov
Re: Construction and drainage plans dated August 9, 2012, prepared by Schwebke — Shiskin &
Associates, Inc. for the proposed West Brickell View development located at, near, or in the vicinity
of the contaminated site G&B Standard Inc. (UT-439/F-7173) 439 SW 8`s Street, Miami, Miami -
Dade County, Florida.
Dear Mr. Mora:
The Department of Regulatory and Economic Resources (RER) has reviewed the above referenced
document received on August 14, 2012 and hereby does not have any objection to the installation of the
proposed drainage system. Be advised that the scope of work provided by the Pollution Remediation
Section (PRS) review is limited to evaluate the location of drainage systems in reference to contaminated
areas. Additional approval from other departments, and/or sections and other governmental agencies
having jurisdiction over the scope of work must be obtained, as applicable, prior to the implementation of
the project. The following conditions shall be incorporated into the approval:
Be advised that in the event that evidence of ground and/or ground water contamination is
encountered, the responsible party or his designee is required to immediately notify PRS at (305) 372-
6700. Furthermore, based on findings, modifications to the drainage design may be necessary.
If you have any questions concerning the above, please contact Gabriel Garcia of the Pollution
Remediation Section at (305) 372-6700.
Sincerely,
Wilbur May7irga, P.E., Chief
Environmental Monitoring and Restoration Division
RER
gg
ec: Mayra De Torres — RER
Michelle Schuyler — RER
'f
.i J
Exhibit D
{00001271.DOCX. 1 }
Introduction
DRAFT
Petroleum Product Indoor Vapor Intrusion Guidelines (interim)
Indoor vapor intrusion (M) refers to vapors emanating from contaminated media (groundwater, soil, or
free product) that migrate through the pore spaces of the soli in the unsaturated zone above the
groundwater table and enter an octupled building through openings such as utility conduits and cracks
In the foundation, resulting In the building occupants being exposed to vapors that could have health
consequences from either acute (short term) or chronic (long term) exposure. The concentration of
vapors which could be of concern due to chronic exposure may be very low and below the threshold of
olfactory detection such that the building occupants may be unaware of the exposure. The
t nsideratian of this pathway of exposure to contamination is a relatively recent development in the
practice of site assessment and remediat!on of contaminated sites.
Draft EPA guidance and other available literature on vapor intrusion evaluation suggests that there is a
real possibility of irdcorvaper Intrusion occurring at buildings both cn a contaminated site and buildings
adjacent to or in dose proximity to a contaminated site; however, it appears that the frequency of
occurrence of problems of petroleum vapors entering off -site buildings through the building foundation
Is retat vely low. The fence related to vapor intrusion evaluation Is still evolving and there will be a
need for the petroleum cleanup program to refine the procedures for vapor intrusion evaluation in the
future when greater knowledge about this pathway is available; however, the available information at
this time on this subject indicates that It is prudent for the Bureau of Petroleum Storage Systems (BPSS)
to establish Interim procedures for evaluation of the potential for indoor vapor intrusion and Identify
measures of rnitlgation.
The current cleanup target levels for Petroleum Products' Contaminants of Concern in soil and
groundwater to qualify for No Further Action without Conditions are believed to be adequately
protective to prevent indoor vapor intrusion, However there is a concern that vapor intrusion may
occur while a site assessment Is being conducted, while the contaminated site is undergoing
remedlation by natural attenuation monitoring or active remedlatlon or due to residual soil or
groundwater contamination when a site receives closure by No Further Action ly.1± Conditions. The
following procedures are Intended to be protective of public health both while site assessment and
remediatlon are underway and after final closure of a site with reslduat contamination remaining under
the provisions of Chapter 62-770.680(2) or (3), F.A.C., for No Further Action with Conditions. The risk
considerations and mitigation measures which may be appropriate for temporary conditions of possible
vapor intrusion while site rehabilitation tasks are underway may be different than for a final closure In
which a source of vapors could be present permanently and result In tong term chronic exposure of
building occupants to vapors to the affected buildings.
APPlkabillte,
At this time the BPSS is requiring these procedures to be applied to eligible sites being funded by the
State of Florida only. The EPSS encourages responsible parties for non -funded contaminated sites to
perform M screening voluntarily.
The most common scenario of a facility at which there Ls a discharge of petroleum products Ls a
commercial petroleum fuel retail sales business with a single occupied building, such as a convenience
store/retail petroleum product sales business on the source property. There may be buildings on ether
properties In the vicinity but are usually greater than 50 feet from the location of the dlscha rge. The
following procedures for evaluation of the vapor Intrusion pathway and identification of appropriate
mitigation measures are based on a facility with these characteristics. Such commercial properties are
usually net very large compared to the Infrastructure improvements such as the tanks, dispensers, and
the building; and the features of the property are laid out for economical use of space such that the.
sources of a petroleum fuel discharge (tanks, dispensers, and Integra€ piping) are usual/ in relatively
dose proximity to the occupied building on the property. Evaluation of the potential far human
exposure to Indoor vapors at the buying !coated at the source property Is complicated by the different
phases of petroleum product contamination that may exist (contaminated soli, c enternlnatad
groundwater and free -phase product floating an the water table) near an occupied building at the
property where the discharge occurred, and also due to the potential for preferential migraticn of
vapors along underground utility tires, which commonly are surrounded by permeable aggro In the
utility trench leading to the occupied building. For these reasons, screening for vapor intrusion potential
based on groundwater ccrrtarninaton concentrations at the source property Is not reliable cr
appropriate.
However, the risk of vapor intrusion to off -site buildings located more than 50 feet from the dischar e
lacetion does lend Itself to an evaluation process in which initial screening for M potential may be
accomplished in mast cases using groundwater contamination concentration data, which need to be
obtained for completing a site assessment under the existing provisions of chapter 62.770.ECO,1=.A.t:.
For this reason, initial screening for vapor intrusion potential at off -site buildings may be ccmpieted with
existing site assessment data such that additional soil vapor sample collection far lei evaluation may not
be necessary in most cases. The reason for this circumstance is that petroleum vapors are highly
biodegradable such that Wave! migration of vapors significant distances from a vapor source
(contaminated sail or free product at the discharge location) to an off -site building more than 50 feat
away from the discharge !cation Is unlikely. For petroleum contaminated sites, the most common
vapor source for buildings on off -site properties is the off -site groundwater contaminant plume which
moves In the direction of groundwater flow and may have migrated beneath an off-slte building. For
off -site buildings more than S0 fret from the location of the discharge, a screening process which
assumes rates of attenuation during vertical migration of vapors between a groundwater plume and the
foundation of a building overlying the groundwater contamination plume, using conservative
assumptions of attenuation rates, Is considered to be a reasonable and economical initial step for
evatuattcn of Ni at the off -site buildings near petroleum contaminated sites.
As indicated above, this screening and mitigation process is based on the most likely scenario of a retaH
petroleum fuel facility with a convenience store building, and that other off -site buildings are located 50
or more feet away from the location of the discharge. For other scenarios of discharges in which
occupied buildings on off -site properties are in close proximity to the location of the discharge, more
Immediate soil vapor assessment and also mitigation measures may be necessary.
Petroleum contaminated sites which already have active remediation underway , or that will have active
remediation implemented within 6 months, which will include provisions for soil vapor mitigation for all
areas potentially affected (e.g. — vapor extraction system) are exempt from these procedures. Other
eligible sites in funding range must perform the Ni screening, and mitigation measures if appropriate.
The nature of vapor intrusion potential at non -petroleum contaminated sites, and to particular,
chlorinated solvent discharge locations, may be very different from petroleum contaminated sites due
to the chemical properties of the chlorirated chernita and because they biodegrade much less readily
than the chemicals found in petroleum products. For this reason, the' Hazardous Waste Cleanup Section
of the Bureau of Waste Cleanup has published separate Ni screening procedures which should be used
for vapor intrusion screening at chlorinated solvent discharge sites.
Assessment of t por Intru3 on Risk
indicator Chemicals — Petroleum fuels are a mixture of many chemicals with varying chemical properties.
The chemical properties that directly affect a chemical's potential to cause a health risk due to indoor
vapor intrusion are volatility, solubility, and toxicity. For these reasons and due to the different fractions
of chemicals in gasoline fuel compared to diesel fuel, sites with a gasoline discharge have a significantly
higher likelihood of having M problems than sites with a diesel fuel discharge. Also, due to its restive
abundance In gasoline fuels, and Its volatility, solubility, and toxicity relative to other chemicals, benzene
is the chemical in gasoline of most concern for the vapor intrusion pathway.
For this reason and because of the conservative assumptions of the iler I smelling process for off -site
buildings described below, only off -site buildings adjacent to petroleum contaminated sites with a
gasoline discharge will initially be subject to these interim screening procedures for IVI, and only
benzene needs to be considered for the Tier 1 evaluation for gasoline discharges. If the site fails the tier
1 mining such that a more advanced screening evaluation for the off -site buildings involving collection
and analysis of soli gas samples becomes necessary, other chemicals found in gasoline fuel and listed In
Table I will also need to be considered.
For M screening at the building of the property where the discharge occurred, significant vapors may be
generated from soli contamination or free -phase product associated with a diesel fuel discharge, and
therefore, if soil vapor screening is conducted at the source property the vapors generated by a diesel
feel discharge need to be considered. The BPSS Is stilt evaluating the need to conduct IVI screening for
circumstances of an off -site building associated with an off -site groundwater plume from a diesel
discharge and will be collecting soil gas samples from the shallow soli above off -site diesel discharge
plumes at selected sites to validate this presurnption and will modify these procedures in the future to
require M screening for off -site buildings asscdated with an off -site groundwater contamination plume
from a diesel fuel discharge if appropriate.
Initial Semite for short distance lateral yaw migration from centamin ll or freeroduct —This
step applies to the source property building and off -site occupied buildings less than 53 feet from the
discharge location. Contaminated sail and free product represent potential sources of relatively high
concentrations of vapors compared to the maximum vapor generation which is possible due to dissolved
petroleum contamination En groundwater. For this reason, occupied bufidln$s located in close proximity
to contaminated soil or free product requires sped consideration for lateral migration of vapors
through the unsaturated zone from the vapor source. Whenever i) the Location of the discharge is
within 50 feet of an occupted building at the source property or 2) is greater than 50 feet from the
building at the source property but the tanks and dispensers have a utility line cannen with the
occupied building, or 3) If there is an off -site occupied building within 50 feet of the discharge location,
the initial phase of the site assessment shout Include collection of shalkaw soil vapor samples (aubsiab
or near foundation shallow soil vapor) near the potentially affected building(s). Soil vapor samps
shcutd be coliected while conducting other site assessment activities and must be collected in
accordance with the attached soil vapor sainpie collection and fiekl 0.A documentation protocol. The
concentrations of Petroleum Products' Contaminants of Concern in the sample results should be
compared with Schedule A of the attached screening Table 1. tf the measured concentration Is less than
the screening criteria, the M patlwray due to vapor migration laterally from contaminated sailor free
product which exists at the location of the discharge is not considered to be complete and no further
evaluation for lilt Is necessary for these buildings. if the screening criterion for any chemical Is
exceeded, it Is recommended that a vapor extraction system be Immediately implemented at the source
property to abate the source of the vapors, or that other nxfgation measures be implemented at each
affected building (see section on litigation beiaw).
funding of mitaticn measures at sites with an elide dischame - For funded sites, if the source
property has an active petroleum storage system, interim mitigation measures to abate vapors near the
building foundation prior to the Implementation of active remedial action will not be funded by the
FDEP. tf there Is no longer an active petroleum storage system at the source property, and the building
at the source property Is residential use or is a commercial building of a nature where the public may be
exposed to vapors for an extended period of time (e.g. —school, day care, nursing home, hospital)
Interim vapor mitigation actions prior to the implementation of active remedial action will be an
allowable cost for FDEP funding. For dreumstances between these extremes, a derision as to whether
funding should be pnevided for interim vapor mitigation until active remedfatIon commences will be
made on a case by case basis. If vapors which exceed the screening levels in Schedule A of Table 1 exist
in the shallow soil in contact with the foundation of an occupied off -site building foundation due to
lateral migration of vapors from the source area of the discharge (contaminated soil or free product)
mitigation measures must be implemented immediately and will be an allowable cost regardless of the
building type.
9ccuoied buildings at off -site properties in the direction of groundwater migration — For off -site
properties with occupied buildings greater than 50 feet from the location of the discharge, the Tier I
evaluation far potential for IVI due to the groundwater to indoor air pathway should be conducted
during the ongoing site assessment and delineation of the groundwater plume that extends beyond
property boundaries. The evaluation must be conducted immediately upon Installation and sampling of
representative monitoring welts which can be used to estimate the maximum groundwater
concentration beneath buildings to conduct the vapor intrusion screening.
Explanation of basis for Tler 1 Scrganine -There is mounting consensus among persons that are
knowledgeable regarding petroleum vapor intrusion evaluation that there is a very significant aerobic
biodegradation contribution to attenuation of vapors between the groundwater table and the building
foundation. However, quantitatively predicting the attenuation of petroleum hydrocarbon vapors
between the groundwater table and the building foundation can be relatively complex, with
considerations of sail type, gradation, and other gecchemistry variables, concentration of ta rget
chemic313 of concern (benzene) compared to total petroleum hydrocarbons in groundwater, background
oxygen demand, and surface covering, among other considerations. Collecting data on these variables
necessitates supplemental assessment and laboratory analysis which can be costly, delays the decision
making, and still results in relatively high uncertainty remaining in the prediction of attenuation based
cn the data collected, which might result in the need for coilect'.cn of soil gas samples near occupied
buildings anyway. It Is desirable to establish an Initial screening step which is based on data which is
collected far off -site groundwater plume delineation under the existing requirements for site
assessment of Chapter 62-770.600 to determine the vapor intrusion pathway is not complete for a
subset of the sites with off -site plumes beneath occupied buildings without incurring additional site
Investigation costs. The screening curve provided in this guidance for screening levels between depths
of 5 feet below building foundation and 40 feet below building foundation based on benzene
concentration and depth to groundwater Is believed to be conservative based on assumptions of the
different variables which may affect attenuation. The screening curve was developed with limited
empirical data from contaminated sites In Florida and a relatively high reliance on various literature
sources on theory of petroleum vapor Intrusion and studies on petroleum vapor migration in the
subsurface in other states. Therefore, at this time the Tier 1 screening curve Is largely intuitively based.
tt is the intent of the BPSS to refine the Tier 1 screening curve based on data collected from
contaminated sites in Florida following the implementation of these procedures. The Tier 1 screening
curve will be revised based on data collected and as a result wffl become more empirically -based and
less intuitively -based.
Tier I - The first evaluation tier is relatively simple and Inexpensive but is based on conservative
assumptions. This screening step Is based on comparison of actual groundwater benzene concentration
end depth to groundwater with a curve which indicates benzene concentrations at depths of between 5
feet below the building foundation and 40 feet below the building foundation for which it is assumed
that petroleum hydrocarbon vapors will not reach the surface and contact the building foundation at
concentrations of concern. if the groundwater Is less than 5 feet below the building foundation and the
groundwater conaentratton exceeds the benzene groundwater CTL (1 ug/L), then the tier 1 screening
step Is not appropriate and Instead the evaluation should proceed to tier 2. If the groundwater table
depth is greater than 40 feet deep below the building foundation and the vapor source Is dissolved
phase groundwater contamination (not free product or soil contamination) then it is presumed that
petroleum hydrocarbon vapors will not reach the'buliding foundation In concentrations of concern
regardless of the dissolved phase concentration of benzene or other petroleum chemicals.
This evaluation should start with the most likely impacted building (Milli) outside of the property that
was the source of the discharge. The MUB wlil have characterisfos of being located close to the
centerline of the groundwater plume and relatively close to the source property such that the bufding
foundation likely has a higher benzene concentration In the groundwater directly beneath the building
than any other off site building. As indicated alcove, if the depth to contaminated groundwater 13 less
than 5 feet below land surface the Tier 1 evaluation is not appropriate and the M evaluation should
procees! to Tier 2.
The concentration of benzene beneath the MUB and the depth to groundwater beta* the building
foundation should be estimated using groundwater monitoring data from wells in close proximity to the
MLIB. Mast buiicengs in Florida are slab on grade construction such that the depth of the grcundwater
below land surface is the same as the depth below the buildir€ foundation. However, the buildlrtg
construction needs to be verified by at least a cursory examination of buttdlrgs In the vicinity during
groundwater sampling events to Identify buildings with a basement. The Tier i screening should be
performed using the attached Figure 1. The depth to grcundwater below the building foundation and
the benzene concentration coordinate for the MUB should be plotted on the figu e. if the depth to
groundwater below the building foundation Is greater than 40 feet or the plotted coordinate Is to the
right of the line on the figure the pathway Is not considered to be complete for any off -site buildings.
However, for funded sites, In order to collect data to validate the Tier 1 screening curve, shallow soil cr
subslab soil gas sarnp:Ses should be collected following; the procedures described In Tier 2 beiaw If the
groundwater concentration Is within 20% of the concentration which would resutt In fail the 71er 1
screening for that groundwater depth (e.g. — for 27i depth below building foundation, the Tier 1 curve
screening threshold Is approximately 5000 ug/L benzene. If the actual concentration for a site with the
groundwater surface at 27 foot depth below the building foundation exceeds 4000 ugJl., soil gas
samples should be collected anyway under the Tier 2 screening procedures described below).' if the
plotted coordinate fails to the !eft of the line on the figure, the evaluation of the MUB must continue
with the Tier 2 evaluation described below. lfthe MUB fags the Tier 1 evaluation then other buildings
ranked by decreasing likelihood of MVI potential based on the estimated groundwater concentration
beneath the building foundation should have the Tier 1 evaluation performed until a building is
Identified for which the pathway is not complete. All buildings which failed. the Tier 1 screening should
proceed to Tier 2.
Tier II —There are two steps that may be followed for completing the Tier tl evaluation and
demonstrating that the NI pathway Is not complete. Because of the nature of the biodegradation
process in the subsurface, the presence of elevated oxygen! levels (near atmospheric levels) in the
shallow sail Is a reliable indicator that petroleum vapors migrating upward from the groundwater table
have been virtually completely degraded before reaching that depth. Therefore the initial step may be
to measure the oxygen level In the shallow sail with a portable 02 meter. Beginning at the MUB, soil
gas sample probes (subslab for saiid or paved surface, shallow sal vapor probe for unpaved surface)
should first be installed following the attached procedures. If the measured 02 level in soil gas samples
collected from the shallow soil or subslab probes Is _96 or higher, then this will be considered an
acceptable demonstration that the petroleum vapors are not in contact with the building foundation
and therefore the IV1 pathway Is not complete and the NI evaluation Is concluded. For eligible sites, sail
gas samples will be collected if the measured 02 level is _46 or less In order to collect empirical data to
validate this screening criterion.
If the 02 reading Is less than _56, thls daes not necessarily mean that the NI pathway is complete but It
will be necessary to collect sail gas samples for analysis to determine ccntaminant levels in the soil gas.
Using the same soil vapor sample probes, samples should be collected following the attached soil vaper
samp collection protocol and completing the sail gas sample tog. The vapor sample results should be
compared to the screening criteria In Schedule A of Table 1. If the allowable shallow soil vapor
concentrations are not exceeded, the Ni pathway is considered to be incomplete and the NI evaluation
pardon cf the site assessment Is concluded. If the concentrations in the shaltcw scil gas at the MUB
exceed the allowable concentrations shown in Schedule A of Table 1, then the NI pathway may be
complete and scil vapor samples should be collected at other buildings which failed the Tier 1 screening
In an order ranked by dearasing likelihood of NI potential based on the estimated maximum
groundwater concentration beneath the building until ail buildings which fail the Tier 2 screening are
Identified.
Mitigative
Within 30 days of identifying occupied buildings which have failed the Tier 2 evaluation, a
recommendation for corrective action needs to be proposed to the FDEP. Any of the following Is an
acceptable strategy.
1. Request approval of alternative procedures to Implement off -site vapor extraction, In advance
of the implementation of the overall active remediatIon strategy, to Immediately reduce vapor
concentrations and air pressure In the subsurface near affected off -site buildings. if this strategy
Is recommended, the Insiailation of the vapor extraction system must begin within 60 days of
authorization by the FDEP.
2. Identify a schedule for expedited site assessment and preparation of a RAP for remediation of
the source property such that remediation of the source property will commence within 6
months and will include off -site vaper extraction which will result In reduced vapor
concentrations and air pressure in the soil beneath the affected buildings.
3. Install a subslab depressurization system at each building which failed the Tier 2 screening.
4. The allowable subslab and shallow soil gas contentxatlons are based on a foundation
attenuation rate of .1, meaning that it is assumed the foundation (and other building
characteristics) will allow vapor transmisslon to the extent that the vapor concentrations in the
building may be 1096 of the soil gas concentration immediately beneath the building; or in other
words, the maximum allowable subslab or shallow son vapor concentration to demonstrate the
iVi pathway Is not complete may be no greater than 10 times the allowable indoor air
concentration. It may be possible to demonstrate the attenuation ability of the subslab is
significantly greater than .1 (meaning attenuation coefficient Is < .1) by performing a radon test.
The radon level should be determined In the subslab gas and In the Indoor air and the ratio of
the two is the building specific foundation attenuation rate. lftthe measured attenuation rate is
Beater than .1 (ratio of indoor air radon level to subslab level le < .1), then site specific subslab
or shallow soil gas concentration limits may be calculated by applying the measured foundation
attenuation to the schedule B Indoor air screening criteria. If the actual petroleum hydrocarbon
concentrations In the subslab gas are less than the site specific subslab cr shallow soil gas
concentrations limits, the IVI pathway is not considered to be cornpiste.
S. Collect Indoor vapor samples to deterrrine whether the pathway Is complete to the !metier of
the buildings that failed the Tier 2 screening. This option is not recommended by the BPSS due
to the confounding effects of background conditions in the bundireg and the Inability to control
the indoor air sample environment of an occupied building. However, if this option Is selected,
the Indoor alr samples should be collected with 6 Itter summa canisters fitted with a regulator to
cellect a composite sample over a 24 hour sample period. The results should be compared to
Schedule B of Table 1 to determine whether the IVI path ray is complete. If the Indoor air
concentraticns exceed the screening criteria of Schedule B of Table 1, one of the first 3
mitigation measures above must be implemented.
lhll ConsIderatorts at the Time of Site Reihaabilltilan Completion
If a site qualifies for No Further Acton without Condfiion s for both soli and groundwater in accordance
with the provisions of Rule 62.770.680(14 F.A.C., no further IVI considerations are necessary. However,
if No Further Anton Ivh Conditions is proposed and soil exceeding soil CTLs remains, or groundwater
exceeding groundwater Ciis remains which Is less than 40 feet deep, then sheik)* soil or subslab soil
gas samples must be collected in the shallow soil at every occupied building on each property which has
residual contamination and Is proposed to be Included In the No Further Action wtth Conditions closure.
If the concentrations are less than the criteria of Schedule A of Table 1, the Site Rehabilitation with
Conditions may proceed. If the concentrations exceed the criteria In Schedule A of Table 1, then site
renhedlatlon must continue until It Ls demonstrated that shallow soil vapor concentrations do not exceed
the applicable criteria, or the engineering and/or Institutional controls which are proposed will Include a
means to prevent vapors from entering occupied buildings on the affected properties.
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httpJ/www.medlarvazdeduaTIM/physics/o %h r/semilogisemilog, 5.gii 12/18/2011
Table 1
Indoor Vapor Intrusion Screening Criteria
Schedule A - Shallow soli gas and subslab vapor screening criteria
Residential Commercial/industrial
Chemical (+ m') (uu/m3)
Benzene 3.1 15.5
•Toluene 4,O00 20,000
Ethylbenzene 22 110
Xylem 210,000 1,050,000
MTBE 30,E 150,003
benzc(b)fluaranthene 0.12 0.6
naphthaene 30 150
2-mathylnaphthalene 700 3,500
Schedule B - Indoor air screening criteria
Res/daTtial Ccmmenial/industrial
Chemical (en) (u3/m3)
Benzene 0.31 1.55
Toluene 400 2000
Ethyibenzene 2.2 11
Xylenes 21,000 1O5,0OO
MTBE 3,000 15,000
benzc(b)flucrant ene 0.012 0.06
naphthalene 3 15
2-methyinaphthatene 70 350
Vapor Sampling Protocol
Vapor sample collection equipment
The following equipment and materials will be utilized for assembling sampling apparatus for vapor
sample collection after a vapor sample probe has previously been installed:
Vartable speed sampling air pump capable of < 1CO ml/min flow rata or non -
variable speed pump with throttling capability and flow meter
Pressure gauge
Vacuum gauge
Tee -valve
Shut off valve
Teflon or polyethylene tubing (1/8 Itch crX inch diameter?)
PID or F1D (PO preferable)
Portable helium detector
Portable landfill gas meter for 02, CO2; and CH4
1 Liter Summa canister fitted by the laboratory with vacuum gauge and
critical orifice flow regutaton device sized to allow sample collection over a
10 minute sample collection time
tadiar bag (optional)
Canister of helium
Schematic of typlcal assembled sampilr apparatus:
(tender development)
Purging and sampling procedure:
Select a purging rate. Maximum flow rate for both purging and sampling will
be 1GO ml/minute or less. Purge rate = PR mi/minute
Calculate system volume (SV) of downhole sampling tube to screen and
volume of sample apparatus tubing —SV ml
Calculate purge volume (PV) = 2X calculated SV, PV ml = 2X SV ml
Calculate purge duration (PD) = (PV ml) / (PR ml/minute)
Conduct initial leakiest of sampling apparatus— Wlth valves at Summa
canister and sampling probe both at the dosed position, turn on sampling
pump and check for whether air flow rate is detected. If air flow is
detected, check fittings or replace tubing and recheck until no air flow rate.
Record vacuum gauge reading.
Conduct purging by opening sample port and running air pump for
calculated PD at PR (100 ml/minute or less)
Measure and record 02, 002, and CH4 during purging
Near the end cf the purging period check the VOC vapors with a PIO or RID
by running purge air through the OVA. Purge flow rate may briefly Increase
above 100 nil/min while OVA reading Is determined. Record OVA reading.
Prior to sample collection a hoed constructed of a box, plastic bag or similar
device should be placed around the top of the vapor probe, Enrich the air
Inside of the hood with tracer gas (helium). Alternatively, a rag may be
saturated with iscpropanal and placed around surface seal cf sampling port.
Shut off purging air pump. Record Initial Surma canister vacuum reading
and open valve on Samna canister. Record start time of sample collection.
Check helium reedi€s during sample collection. (If reading indicates air
concentration is > 10 % heiitim suspend the sample collection and reseal
sample port. Start over with a new sum ma canister.) Summa canister will
be fitted by the laboratory whit vacu m gauge and critical orifice flow
regulation device sized to allow sample collection over a 10 minute sample
collection time. Shut off Surma canister Wive between 8 and 9 minutes so
that there is residual vacuum left in the Summa canister. Residual vacuum
should be approximately 1 to 5 Inches of tfg. Record residual vacuum.
Calculate volume of sample collected (sample time X sample flaw rate) and
record.
If sampling with a tedlar bag Instead of Surnrna canister, connect tediar bag
downstream of air pump after purging is concluded and continue sample
collection at < 1I30 mi/min pumping rate.
Complete sampling leg and chain of custody form and send sample to lab
for analysis with EPA method TO-15.
Thoroughly decontaminate valves, fittings, vacuum gam, air sampling
pump and other meters with "zero" air provided by laboratory. Discard
apparatus tubing downstream of sampling pert and use new tubing for next
sample event.
SOIL GAS SAMPLING LOG
FACILITY NAMZ
FDEP FACILITY ID*
FACILITY LOCATION:
DATE
AIR TEMPERATURE (°F):
BAROMETRIC PRESSURE (Inches Kg):
PRECIPITATION (Imbed):
WIND CONDIT'I0N4:
SALE LOCATION! IDENTIFICAT1CNr
SAMPLE DEPTI4 pass):
FIELD PERSONNEL: NAI E($) (prtrrt) / AFFILIATION: SIGNATURE(S):
PURGING DATA
"MVO MATERIAL:
TUBING INTERNAL DIANETE32 (}oche):
TUBING LENGTH (Irsths):
TUBING 'VOLUME (Tr R=X trbirtg Ierth):
EDUIPMENT MOLINE ■ SANG APPARATUS VOLUME + Tt BUNG VOLUME = .
(rrccrmnarted pirg Worm = 2 tree eau4mentvolmrx)
PURGING tNmATEDAT:
PURGING ICED AT:
PUS RATE
(rni train) Drsax3musf 12Ci:
Tt3TAL Vaf r risc
PURGED (mL):
DVA READING
AT END OF PURGE (pan):
02 % or p m (cite a ore) '
CO2 % or pool (drde one)
METHANE % or gm (c4c go)
Tans
Roacbg
Toro
RegIng
The
Ram
Dam IN
For ether dfamet
lIbetaiiiaearfootx 113" a 2.3; 311r it el; IM" at 9.8;
611$"a18.1; sir =22.7; 1i3"'■37.9; la" ■60.8
foot
AL DIAMETER CAPACITY (rm
— (W2) X 618 a rnii inear
SAMPUNG DATA
SAMPLE CONTAINER TYPE (droll) ma): TEDLAR BAG SU IIA CANISTER
SAMPLE CONTAINER SIZE (care* one) 1 LITER 8 LITER OTHER (goody):
SAMPLING INITIATED AT:
SAMPLING ENDED AT:
SAMPLE CONTAINER FLOW RATE (rnlhnn):
S* 9 DM CANISTER OW : STAFMNG VACUUM PRESSURE Inches
RIDING VACUUM PREP: Indus
Hg or inches H2O (date cn.)
Ha or Inches H2O Oita are)
TRACE? IVATERIAL USED ( one): HELIUM tS0FROPANCI. OTHER (specify):
LEAKS OBSERVED (circta one): YES (provide doles betcw) NO
REMARK
Exhibit E
{00001271,DOCX. 1}
Michael Goldstein
From: Justin Hofmeister
Sent Wednesday, December 12, 2012 1:46 PM
To: Justin Hofmeister
Subject: FW: WM extension in front of contaminated site UT-528
Attachments: Ramirez 66 Site Map.pdf - Adobe Acrobat Professional.pdf
From: Mas, Jose (PERA)
Sent: Friday, February 17, 2012 10:02 AM
To: Mas, Jose (PERA)
Subject: FW: WM extension in front of contaminated site UT-528
From: Garda, Gabriel (PERA)
Sent: Wednesday, February 15, 2012 1:46 PM
To: Llano, Jackie (PERA)
Subject: RE: WM extension in front of contaminated site UT-528
Good Afternoon Enrique,
Please see below for information regarding the contaminated site found in the vicinity of the construction project. The
information we provide is based on the information available in PERA's records.
• Brickell Trading Post Inc. (former Ramirez 66 Service Station), Folio: 01-4138-051-0450, 1245 SW 2nd
Avenue, UT-528/F-7243:
According to PERA files, petroleum contamination was discovered as a result of tank excavations in November
1992. Please see the site plan for the location of the underground storage tanks. A Site Assessment Report has
never been submitted for this property.
If you have any questions please feel free to contact me.
Regards,
Gabriel Garcia, EL, Hydrogeologist II
Miami -Dade County Permitting, Environment and Regulatory Affairs
Pollution Control Division/Pollution Remediation Section
Overtown Transit Village
701 NW 1st Court, Your Location (4th Floor), Miami, Florida 33136
(305) 372-6700
www.miamidade.pov/pera
"Delivering Excellence Every Day"
Please consider the environment before printing this email.
Please consider the environment before printing this e-mail.
1
•
MEMORANDUM
•
TO: Judie Kean, Program Manager
Bureau of Waste Cleanup, FDER
FROM: M. Paul Voight, Project Supervisor
State Administered Cleanup Program
Pollution Prevention and Control
Division
Dom: April 21, 1992
SUBJECT: SACP Site assignment
for IRA only
The following site is submitted to FDER for assignment consideration to
conduct IRA/tank removal activities only:
Ramirez 65
1245 SW 2 Avenue
Miami, Florida 33130-4213
DER FAC No. 138841817
DERM 0T-0528
This site is currently approved for State Cleanup but has a low acore (11).
Fuel sales were discontinued July 1989. Diasalved contamination was
documented by DERM in January 1990 (3enz/BTEX - 845/2195). Some product
remains in tanks; possible ongoing discharge. DERM is presently pursuing
enforcement action for non -properly abandoned tanks (four gasoline tanks,
one waste oil tank and one kerosene tank).
Affidavit states owner is 75 year old widow with no assets for tank removal
or abandonment. Seventeen year lessee recently abandoned facility; owner
wishes to sell property but cannot afford to comply with DERM requirement of
tank removal.
Please let me know if this site is acceptable for assignment.
MPV:
SAC-FDER memos/SAC-0528
Environmental FirstSearch
Site Detail Report
Target Property. 1026 SW 2ND AVE
MIAMI, FL 33130
JOB: FTL-11-0801
LU ST
SEARCH ID: 32
DIST/DIR: 0.16 SE ELEVATION: 15 MAP ID: 6
NAME BRICKELL TRADING POST INC REV: 7/18/12
ADDRESS: 1245 SW 2ND AVE ID1: 138841817
MIAMI FL 33130 102: 8841817.00
MIAMI-DADE STATUS: FACILITY OPEN
CONTACT: PHONE: (305) 856-1455
SOURCE FL DEP
SITE INFORMATION
OPERATOR:JESUS RAMiEREZ
NAME UPDATED:10/17/2003
ADDR UPDATED:04/25/2006
BAD ADDR INDICATOR:N
RP ID:50329
RP ROLE:A000UNT OWNER
RP BEGIN:06/23/2000
NAME:BRICKELLTRADING POST INC
1245 SW 2ND AVE
MIAMI FL 33130
PHONE:(305)856-1455
DISCHARGE INFORMATION
DISCHARGE DATE:07/16/1988
COMBINED:
SCORE:11
SCORE DATE:11/04/1997
CLEANUP REQUIRED:R - CLEANUP REQUIRED
WORK STATUS:ACTIVE
DISCHARGE CLEANUP STATUS:RA - RA ONGOING
INFO SOURCE:E - EDI
OTHER SOURCE:
SITE MANAGER:
MANAGER END DATE:
TANK OFFICE: -
APPLICATON RECD:11/4/1988
ELIGIBILITY STATUS:E
ELIGIBILITY DATE:3/1/1990
LETTER OF INTENT:
EUG LETTER SENT:03/01/1990
REDETERMINED:N
INSPECTION DATE:06/30/1989
DEDUCTIBLE AMOUNT:
DED PAID TO DATE:0
CO PAY AMOUNT:
CO -PAID PAID TO DATE:0
CAP AMOUNT:
UST INFORMATION
THIS SITE IS CURRENTLY REGULATED BY CHAPTER 62-761, F.A.C.
- Continued on next page -
Site Details Page - 7
Environmental FirstSearch
Site Detail Report
Target Property: 1026 SW 2ND AVE
MIAMI, FL 33130
JOB: FTL-11-osol
LUST
SEARCH ID: 32 DIST/DIR: 0,16 SE ELEVATION: 15 MAP ID: 6
NAME: BRICKELL TRADING POST INC REV: 7/18/12
ADDRESS: 1245 SW 2ND AVE 101: 138841817
MIAMI FL 33130 ID2: 8841817.00
MIAMI-DADE STATUS: FACILITY OPEN
CONTACT: PHONE (305) 856-1455
SOURCE: FL DEP
TOTAL NUMBER OF TANKS: 6
TANK INFORMATION
TANK ID:1 STATUS:OPEN
TVI:TANKDEP CO:NO
INSTALLED:STAT DATE:
TK STAT:B - REMOVED
CAPACITY(GAL):2CCO
CONTENT:B - UNLEADED GAS
PLACE:UNDERGROUND
TYPE:A - RETAIL STATION
TANK ID:2STATUS:OPEN
TVI:TANKDEP CO:NO
INSTALLED:STAT DATE:
TK STAT:B - REMOVED
CAPACITY(GAL):2C00
CONTENT:B - UNLEADED GAS
PLACE:UNDERGROUND
TYPE:A - RETAIL STATION
TANK ID:3STATUS:OPEN
TVI:TANKDEP CO:NO
INSTALLED:01-JUL-1960STAT DATE:
TK STAT:B - REMOVED
CAPACITY(GAL):4000
CONTENT:B - UNLEADED GAS
PLACE:UNDERGROUND
TYPE:A - RETAIL STATION
TANK ID:4STATUS:OPEN
TVI:TANKDEP CO:NO
INSTALLED:01-JUL-1973STAT DATE:
TK STAT:B --REMOVED m�---=-
CAPACITY(GAL):4C00
CONTENT:B - UNLEADED GAS
PLACE:UNDERGROUND
TYPE:A - RETAIL STATION
TANK ID:5STATUS:OPEN
TVI:TANKDEP CO:NO
INSTALLED:01-APR-2000STAT DATE:01-APR-2C00
TK STAT:U - IN SERVICE
CAPACITY(GAL):12000
- Continued on next page -
Site Details Page - 8
Environmental FirstSearch
Site Detail Report
Target Property: 1026 SW 2ND AVE JOB: FTL-11-0801
MIAMI, FL 33130
LUST
SEARCH ID: 32
DIST/DIR: 0.16 SE ELEVATION: 15 MAP ID: 6
NAME BRICKELL TRADING POST INC REV: 7/18/12
ADDRESS: 1245 SW 2ND AVE ID1: 138841817
MIAMMI FL 33130 ID2: 8841817.00
MIAMI-DADE STATUS: FACILITY OPEN
CONTACT: PHONE (305) 856-1455
SOURCE: FL DEP
CONTENT:8 - UNLEADED GAS
PLACE:UNDERGROUND
TYPE:A - RETAIL STATION
TANK ID:6STATUS:OPEN
TVI:TANKDEP CO:NO
INSTALLED:01-APR-2000STAT DATE:01-APR-2G00
TK STAT:U - IN SERVICE
CAPACITY(GAL):12000
CONTENT:8 - UNLEADED GAS
PLACE:UNDERGROUND
TYPE:A - RETAIL STATION
5F - FIBERGLASS CLAD STEEL
5M - SPILL CONTAINMENT BUCKET
5N - FLOW SHUT-OFF
5P - LEVEL GAUGES/ALARMS
5R - DOUBLE WALL - TANK JACKET
6F - FIBERGLASS CLAD STEEL
6M - SPILL CONTAINMENT BUCKET
6N - FLOW SHUT-OFF
6P - LEVEL GAUGES/ALARMS
6R - DOUBLE WALL - TANK JACKET
PIPING INFORMATION
TANK ID:DESCRIPTION:
5C - FIBERGLASS
5F - DOUBLE WALL
5J - PRESSURIZED PIPING SYSTEM
5K - DISPENSER LINERS
6C - FIBERGLASS
6F - DOUBLE WALL
6J - PRESSURIZED PIPING SYSTEM
6K - DISPENSER LINERS
MONITORING INFORMATION
TANK ID:DESCRIPTION:
56 - EXTERNAL PIPING MONITORING
5F - MONITOR DBL WALL TANK SPACE
5G - ELECTRONIC LINE LEAK DETECTOR
5K - MONITOR DBL WALL PIPE SPACE
5N - GROUNDWATER MONITORING
66 - EXTERNAL PIPING MONITORING
6F - MONITOR DBL WALL TANK SPACE
6G - ELECTRONIC LINE LEAK DETECTOR
6K - MONITOR DBL WALL PIPE SPACE
6N - GROUNDWATER MONITORING
Site Details Page - 9
Exhibit F
{00001271.DOCX. 1 }
BR•ARD
-- COUNTY
FLORIDA
Environmental Protection and Growth Management Department
POLLUTION PREVENTION, REMEDIATION AND AIR QUALITY DIVISION
One North University Drive, Suite 203, Plantation, Florida 33324
954-519-1260 • FAX 954-765-4804
EAR SECTION STANDARD OPERATING PROCEDURE FOR DEWATERING
(Revision 3, Effective December 1, 2009)
INTRODUCTION
As required by Broward County Code (Code?, any person(s) wishing to conduct dewatering activities at or within a
one -quarter -mile radius of a contaminated site must notify and receive approval from the Broward County
Environmental Protection and Growth Management Department (Department) prior to implementation. The
County's notification requirements for these dewatering activities are outlined in Section 27-355(4) of the Code,
which states:
"Prior to any persons conducting dewatering operations at or within a one -quarter -mile radius of a contaminated site,
written notification shall be given to [the Department] and shall include, at a minimum:
• Justification for the need for dewatering;
• Water treatment and disposal plans;
• Effect of the dewatering and disposal procedures on the contaminant plume;
• Monitoring program; and
• Where required and authorized by Chapter 471, F.S. [Florida Statutes] or Chapter 492, F.S., applicable portions
of dewatering plans shall be signed and sealed by a registered professional engineer or a registered professional
geologist."
Approval of such activities is required by Section 27-353(i) of the Code, which states:
"Dewatering operations at or within a one -quarter -mile radius of a contaminated site shall not be conducted without
[Department] approval."
APPLICABILITY
This Standard Operating Procedure (SOP) and the requirements detailed herein are applicable to dewatering
operations within Broward County. "Dewatering" refers to any technique that is employed to lower groundwater
level. These requirements apply solely to reviews that are conducted by Broward County Environmental
Assessment and Remediation (EAR) Staff for the purpose of ensuring that dewatering operations at or within one -
quarter mile of contaminated sites will not result in the exacerbation, migration, or improper treatment of
contamination. Please note that additional requirements for dewatering have been established by other agencies and
may be established by other Sections within the Department.
Tank Upgrade Exemption
Dewatering operations conducted to facilitate underground storage tank upgrades and replacements necessary to
meet the Performance Standards for Category -A and Category-B Storage Tanks of Section 27-307(b), Broward
County Code, and Section 62-761.510, Florida Administrative Code (F.A.C.), are exempt from the EAR Section
Dewatering Plan review and approval process. To qualify for this exemption, a Notice of Intent to Dewater must
"Contaminant" is defined in Section 27-352, Broward County Code
Broward County Board of County Commissioners
Sue Gunzburger • Kristin D. Jacobs • Albert C. Jones • Ken Keetlil • Ilene Lieberman • Stacy Ritter • John E. Rodstrom, Jr. • Diana Wasserman -Rubin • Lois Wexler
www.broward.org
EAR SECTION STANDARD OPERATING Page 2 of 7
PROCEDURE FOR DEWATERING
be provided to EAR Section staff at Least five (5) business days prior to dewatering. The Notice of Intent to
Dewater must agree to the following conditions:
1. Dewatering duration must not exceed a total of three (3) calendar days (72 hours). If intermittent
dewatering is performed, this duration is be considered to be the sum of all actual pumping periods,
however clarification should be provided in the Notice of Intent to Dewatering with respect to the overall
period that dewatering will be performed;
2. Sheetpile must be installed to a depth not less than 8 feet below the bottom of wellpoint screens;
3. Effluent must be monitored to ensure compliance with turbidity standards, as applicable; and
4. If conducted within a tank farm area known to be contaminated, dewatering effluent must be properly
treated and monitored to comply with water quality standards or applicable Cleanup Target Levels of
Chapter 62-777, Florida Administrative Code, prior to discharge. Treatment system specifications,
laboratory analytics, field notes, and other relevant documentation should be maintained by the party
responsible for performing the dewatering.
Any exceptions to conditional items 1 and 2 of this exemption will require the Department's approval of a
Dewatering Plan submitted per this SOP. If contamination is encountered during the tank upgrade which has not
been previously reported to the Department, dewatering must cease and the Department must be notified in
accordance with the requirements of Code Section 27-355.
PROCEDURE
A flow chart which demonstrates this SOP is depicted in Exhibit I, attached. Please note that Exhibit I does
not address the tank upgrade exemption as detailed in the previous section.
I. Need for EAR Section Approval of Dewatering Operations
A. For sites located beyond one -quarter mile of a contaminated site in Broward County, the Department does
not include a "No Dewatering Permitted" clause in construction plan approvals. Dewatering may proceed at
such sites; however, it is recommended that EAR Section staff be notified for confirmation.
B. In instances where dewatering is proposed within a contaminated area (i.e., where it is known that
groundwater contains contaminants above applicable standards) but where no other contaminated sites are
located within one -quarter mile, a Dewatering Plan must be submitted to the EAR Section of the
Department for review and approval prior to implementation of dewatering activities; however, the
Dewatering Plan should only contain the following:
1. The contaminated site information outlined in Section ILA. of this SOP for the dewatering location,
2. The information outlined in Section II.B. of this SOP, and
3. Proper certification as required by Section II.E. of this SOP.
A Dewatering Report to document the dewatering is also required by Section IV of this SOP.
C. For sites that are located within one -quarter mile of a contaminated site, a Dewatering Plan in accordance
with Section II of this SOP must be submitted to the EAR Section of the Department for review and
approval prior to implementation of dewatering activities. Dewatering will not be approved under any
conditions for operations that may create a drawdown greater than 0.1 foot at a contaminant plume
boundary. The Dewatering Plan must meet the requirements established in Section II of this SOP.
II. Dewatering Plan Requirements
A. Contaminated locations at and/or within one -quarter mile of the proposed dewatering project must
be identified. At the time of this writing, the Broward County contaminated sites database and
corresponding interactive map are available on the interne at http://www.broward.org/
pprd/contaminated_sites.htm.
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EAR SECTION STANDARD OPERATING Page 3 of 7
PROCEDURE FOR DE WATERING
The following items should be included in the Dewatering Plan:
1. Site Number and address for each contaminated site,
2, Contaminant type for each contaminated site,
3. Most recent contaminant plume maps for all groundwater -contaminated sites located within a quarter -
mile radius from the proposed dewatering location (if available),
4. Tables of the most recent groundwater analytical data for the nearest groundwater -contaminated site (if
available), and
5. A map, drawn to scale, that depicts the particular dewatering location on the site (designation of the site
boundaries in general is not adequate) and the locations of identified contaminant plumes.
If contaminant plume maps and data are not available through hardcopy file review with the Department,
the Florida Department of Environmental Protection, or the OCULUS petroleum document website (at the
time of this writing, Iocated at http://dwmedms.dep.state.fl.us/Oculus/servlet/login), then document this fact
in the Dewatering Plan and assume that the contaminant plume is confined to the property boundary of the
particular contaminated site.
B. The following information must be provided regarding the scope of the proposed dewatering
activities:
1. Purpose of dewatering (i.e., an explanation of why dewatering is necessary),
2. Dewatering technique (i.e., wellpoint, deep weII, open hole, etc.),
3. Anticipated dewatering flow rate,
4. Total dewatering duration,
5. Method of effluent discharge,
6. Controls (i.e., settling tank, turbidity curtain, etc.) and a monitoring program employed to ensure that
effluent will comply with applicable water quality standards, including turbidity.
7. If conducted in a contaminated area, engineering specifications for dewatering effluent treatment (i.e.
air -stripper, carbon filtration, etc.) and details for an analytical monitoring program to ensure that
effluent will meet water quality standards established by Section 27-195, Broward County Code.
Please note that Certification by a Florida -registered Professional Engineer, specifically, is required for
treatment specifications by Section II.E. of this SOP.
8. A description of any proposed controls, including engineering specifications for sheetpile or recharge
system. Certification by a Florida -registered Professional Engineer is required for applicable sheetpile
specifications by Section II.E. of this SOP.
C. Dewatering plans must contain a technical justification that is adequate to demonstrate the proposed
scope of dewatering (as required in Section II.B.) will not affect contaminant plumes. There are two
(2) acceptable methods for providing this technical justification:
1. Manual estimations of the dewatering radius of influence by utilizing SFWMD data or approved
aquifer test data to calculate Sichardt's equation. As a "first pass" of technical justification,
Sichardt's equation may be used to determine the radius of influence associated with the dewatering
project as discussed in Section II.C.1.b. of this SOP. Details of Sichardt's equation, including an
example calculation, are also included as Exhibit III to this SOP. The calculation must utilize 1) data
from South Florida Management Water District's (SFWMD) Technical Publication 92-05 entitled, "A
Three Dimensional Finite Difference Groundwater Flow Model of the Surficial Aquifer System,
Broward County, Florida" (1992), or 2) data provided by an aquifer test conducted in accordance with
Section II.C. I .a. of this SOP.
a. Aquifer test performance and data collection must be consistent with the following guidance:
Freeze and Cherry (1979), Fetter (1980), Kruseman and Derrider (1990), or Driscoll (1986). EAR
Staff will use AQTESOLV (for Windows) to verify aquifer parameters that are generated from
Broward County Board of County Commissioners
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PROCEDURE FOR DEWATERING
hand calculations and/or computer modeling analysis of aquifer tests. Aquifer Test Data may be
collected in one of three (3) ways:
(1) Historical aquifer test data from the EAR Section's in-house database may be obtained by
contacting David Vanlandingham, P.E., at (954) 519-1478 or dvanlandingham@broward.org.
The information contained in the EAR Aquifer Test database has been reviewed by EAR
Section staff for quality assurance.
(2) Other historical aquifer test data may be submitted if the test was performed within one -quarter
mile of the proposed dewatering location and:
(a) Groundwater elevations were measured in at least three (3) observation wells (not including
the test well) with varying distances from the recovery well,
(b) Data is collected from the beginning of the test until near steady-state conditions are
achieved, and
(c) Unconfined aquifer conditions and partially penetrating wells were considered in analysis
of the aquifer test data2.
(3) Perform an aquifer test at the proposed dewatering location. Notification must be provided
using Exhibit II and written approval must be obtained from EAR staff prior to implementation
of the aquifer test. Approvals may be granted through email or facsimile. The test data will be
acceptable if the conditions of Section II.C. I .a.(2) are met; in addition,
observation wells are to be installed in a line between the dewatering locations and the nearest
identified contaminant plume}, and
one of the observation wells is located at the edge of the proposed dewatered area.
b. Utilizing Sichardt's equation, a manual (hand) calculation may be performed to determine the
projected radius of influence associated with the proposed dewatering activity and the flow rate
necessary to produce the required drawdown. This calculation is detailed in Exhibit III
accompanying this SOP.
(1) If the estimated value of radius of influence is less than the distance to the edge of the nearest
contaminant plume, the Dewatering Plan may be approved (an example approval letter is
provided in Exhibit IV).
(2) If the estimated radius of influence is greater than the distance to the edge of the nearest
contaminant plume, then groundwater modeling is required pursuant to Section II.C.2. of
this SOP. The dewatering scope of work may also be revised or hydraulic controls (for
instance, sheetpile or artificial groundwater mounding via recharge trenches or wells) may be
proposed; however, any hydraulic controls proposed must still be justified through the use of
computer modeling in accordance with Section II.C.2. of this SOP, as manual calculations
which consider hydraulic controls are not available'.
2. Groundwater modeling within a three-dimensional computer model utilizing SF'WMD data or
approved aquifer test data. The model framework must utilize 1) data from South Florida Water
Management District's (SFWMD) Technical Publication 92-05 entitled, "A Three Dimensional Finite
Difference Groundwater Flow Model of the Surficial Aquifer System, Broward County, Florida"
(1992), or 2) aquifer test data obtained in accordance with in Section II.C. I .a. of this SOP.
2 If these conditions are not met, the test data may be reanalyzed by the applicant via a method that will consider
unconfined aquifer and partially penetrating well scenarios.
3 These observation points may also be used to meet the requirements of groundwater monitoring, as outlined in
Section II.D. of this SOP.
4 The manual calculation method cannot be used for sites where artificial groundwater mounding is proposed as a
hydraulic control. Artificial groundwater mounding as a means of hydraulic control may only be justified through computer
modeling as outlined in Section II.C.2. of this SOP.
Broward County Board of County Commissioners
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EAR SECTION STANDARD OPERATING Page 5 of 7
PROCEDURE FOR DEWATERING
All models, regardless of the software used to construct them, are to be properly documented. The
Division will use Visual. MODFLOW Pro to verify all modeling analyses. Any Dewatering Plan that
includes computer modeling must also contain the following information, as applicable:
a. A compact disc with a copy of all model data including all necessary input, support, and output
files.
b. Map file used as base coverage in .dxf or .bmp format.
c. Model domain including the number of columns, rows, and layers. Grid spacing must also be
documented for areas of the model with increased cell resolution.
d. Model extent including X-axis, Y-axis, and Z-axis minimum and maximum. Also include
coordinates (Lat/Lon, UTM, State Plane) if the model extent are referenced to specific geographic
locations. The model should cover a sufficient area as to allow for a true representation of ground
water flow during dewatering without undue influence from boundary conditions.
e. Model units for length, time, conductivity, pumping rate, mass, and concentration as applicable.
f. Surface elevation and bottom elevation of all layers. If layer elevation is not a constant, then submit
a spreadsheet containing x, y, z data in either .txt or .xls format or as a Surfer® .grd file.
g. Conductivity values of all layers including Kx, Ky, and Kz. If conductivity data vary within a layer
then submit a file in .txt, .xls, or .shp format. Also include all data interpolation information as
applicable. If layer elevation is not a constant, then submit a spreadsheet containing x, y, z data in
either .txt or .xls format or as a Surfer® .grd file.
h. Specific Storage (Ss) and Specific Yield (Sy) values of all layers. If Ss and/or Sy data vary within a
layer, then submit a file in .txt, .xis, or .shp format. Also include all data interpolation information
as applicable.
is Porosity and effective porosity values of all layers. If porosity and/or effective porosity data vary
within a layer, then submit a file in .txt, .xls, or .shp format. Also include all data interpolation
information as applicable.
Pumping well specifications including exact map coordinates, screened interval, pump rate, and
pumping duration.
k. Head observation well specifications including exact map coordinates, screened interval,
observation point elevation, and all water table elevation measurements.
1. Concentration well specifications including exact map coordinates, screened interval, contaminant
being monitored, observation point elevation, and all concentration measurements.
m. The type (constant head, rivers, general head, drains, walls, etc.) and model -grid location for all
boundary conditions including an explanation of their selection and description of their input
parameters. Boundary conditions should be defined as to not artificially influence ground water
flow in the dewatering area or nearby contaminated sites.
n. Acknowledgment that the model ignores recharge to maintain a conservative estimate of
dewatering influence.
o. Particle tracking information including number of particles, initial particle locations, and release
times if applicable. All particles are to be tracked in the forward direction.
p. If Zone Budget is used to estimate a dewatering flow rate, then the number and model -grid location
of zones and output information must be included, as applicable. The type of model run (Steady
State Flow or Transient Flow) must also be specified. The Division recommends running the model
using only documented boundary conditions under Steady State Flow to determine initial heads.
Transient Flow should be used for the duration of proposed dewatering.
q. The time steps utilized during Transient Flow model runs.
r. Figures showing model output as both Head Equipotentials and Drawdown at the end of the
proposed dewatering period for each modeled layer.
s. A figure identifying the 0.1-foot and 0.01-foot dawdown contours at the end of dewatering.
D. The Dewatering Plan must propose a groundwater monitoring program subject to the following:
1. Should a manual estimation of the radius of influence performed in accordance with Section II.G.1. of
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EAR SECTION STANDARD OPERATING Page 6 of 7
PROCEDURE FOR DEWATERING
this SOP indicate that the radius of influence is less than the distance to the nearest contaminant plume,
no monitoring program is required (an example approval letter is provided in Exhibit IV).
2. Should modeling performed in accordance with Section II.C.2. of this SOP indicate that the closest
groundwater contaminant plume is outside of the 0.01-foot drawdown contour, no monitoring program
is required (an example approval letter is provided in Exhibit IV).
3. Should modeling performed in accordance with Section II.C.2. of this SOP indicate the closest
groundwater contaminant plume lies between the 0.01-foot and 0.1-foot drawdown contours, a
monitoring program is required (Exhibit IV will be modified by the Division to reflect specific
requirements). The monitoring program must include:
a. A table of groundwater elevation data collected from a minimum of three observation points,
placed on a line between the dewatering location and the nearest contaminant plume. Data shall be
collected:
(1) Prior to initiating dewatering activities to establish baseline elevations. Locations that are
tidally influenced may require more than one baseline monitoring event.
(2) Daily during the first week of dewatering activities, and weekly thereafter until dewatering
operations cease. The applicant should make every effort to collect data at the same time of day
to reduce the influence of daily fluctuations.
b. A map, drawn to scale, detailing the observation point locations relative to the dewatering project,
and
c. A map, drawn to scale, including water table elevations from observation points and an indication
of ground water flow direction.
4. Should a manual estimation of the radius of influence performed in accordance with Section II.C.I. of
this SOP indicate that the radius of influence is greater than the distance to the nearest contaminant
plume, or should modeling performed in accordance with Sections II.C.2. of this SOP indicate that the
closest contaminated plume lies within the 0.1-foot drawdown contour, dewatering will not be
approved by the Division. The Dewatering Plan may be revised or hydraulic controls (i.e., sheetpile
cofferdam or artificial groundwater mounding via recharge) must be proposed and justified. If in this
event, hydraulic controls are proposed, computer modeling must be performed in accordance with
Section II.C.2. of this SOP, as manual calculations that consider hydraulic controls are not availables.
E. All applicable portions of Dewatering Plans must be certified by a registered Professional Engineer
or a registered Professional Geologist, as provided in Chapter 471, F.S., or Chapter 492, F.S.
F. The Dewatering Plan must contain the contact information for the entity that is assuming
responsibility for the specified conditions of the Department's approval. The company name, a
representative name, address, and phone number should be included, as applicable.
G. There is no review fee or "application" for the Dewatering Approval. Simply submit one (1) certified
original of the Dewatering Plan to the Department, to the attention of David Vanlandingham, P.E., at this
letterhead address.
III. EAR staff shall have a period of ten (10) business days to review Dewatering Plans submitted pursuant to
this SOP and to provide comment and/or approval.
IV. A Dewatering Report must be submitted within thirty (30) days of completion of approved dewatering
activities to document actual flow rates and field monitoring data, including any monitoring conducted pursuant
to Sections II.B.6., II.B.7, and II.D. of this SOP.
5 The manual calculation method cannot be used for sites where artificial groundwater mounding is proposed as a
hydraulic control. Artificial groundwater mounding as a means of hydraulic control may only be justified through computer
modeling as outlined in Section II.C.2. of this SOP.
Broward County Board of County Commissioners
Sue Gunzburger • Kristin D. Jacobs • Albert C. Jones • Ken Keechl • Ilene Lieberman • Stacy Ritter • John E. Rodstrom, Jr. • Diana Wasserman -Rubin • Lois Wexler
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EAR SECTION STANDARD OPERATING Page 7 of 7
PROCEDURE FOR DEWATERING
References
Chapter 27 of the Code of Ordinances of Broward County, Florida. Tallahassee, Florida: Municipal Code
Corporation, 2001.
Driscoll, Fletcher G. Groundwater and Wells (Second Edition). St. Paul, Minnesota: Johnson Filtration Systems,
Inc., 1986
Fetter, C.W. Applied Hydrogeology (Third Edition). New York, New York: Macmillian College Publishing Co.,
1994.
Geraghty & MilIer, Inc. AQTESOLV. Reston, Virginia: James O. Rumbaugh, III, developer.
Freeze, R. Allan, and Cherry, John A. Groundwater. Englewood Cliffs, New Jersey: Prentice Hall, 1979.
Kruseman, G.P., and De Ridder, N.A., Analysis and Evaluation of Pumping Test Data. Wageningen, The
Netherlands: International Institute for Land Reclamation and Improvement/ILRI, 1990.
Powers, J. Patrick, P.E. Construction Dewatering: New Methods and Applications - Second Edition. New York,
New York: John Wiley & Sons, 1992
South Florida Water Management District (SFWMD). A Three Dimensional Finite Di erence Groundwater Flow
Model of the Surficial Aquifer System, Broward County, Florida. West Palm Beach, Florida: Technical Publication
92-05, 1992.
Waterloo Hydrogeologic. Visual MODFLOW Pro (v.3.0.0). Waterloo, Ontario, Canada.
Broward County Board of County Commissioners
Sue Gunzburger • Krislan D. Jacobs • Albert C. Jones • Ken Keedtl • lien Lieberman • Stacy Ritter • John E. Rodstrom, Jr. • Diana Wasserman -Rubin • Lois Wexler
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