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Hazardous
Rehabilitation of Petroleum Products
Numerous technologies are now
available to address petroleum contamination; a prudent evaluation and selection
is necessary for an effective cleanup.
The rehabilitation of sites with petroleum contamination is an interesting and
recurring problem that needs to be addressed as effectively as possible. As
many different technological solutions can be utilized and each contamination
site is somewhat unique in its problems and characteristics, a careful and
detailed study of the available information is necessary to arrive at the
optimal solution. Site remediation treatment technologies such as
bioremediation, soil vapor extraction, thermally enhanced recovery, dual phase
air sparged systems and other more exotic methods are constantly being
developed to effectively meet varying contamination scenarios and treatment
and cost efficiency requirements. The methodology and system that most
effectively solves the existing contamination problem and is within budget
need to be selected. Field supervision to ensure the correct erection and
operation of the system is also of paramount importance to ensure that the
cleanup goals will be met and the schedule maintained. In the paragraphs that
follow, some of the approaches OHC would utilize to remediate petroleum
contaminated sites are discussed, along with some case studies and
methodology.
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Gas Station Contamination
The average gas station is
about one-half of an acre, 200' by 250' and has the potential to cause
considerable contamination.
Typical gas stations are about one-half of an acre and are rectangular parcels
of land that are about 200' by 250' located mostly at intersections. The
parcel of land accommodates the office and or convenience food store, the pump
islands, sometimes a car-wash and some repair shop and the underground storage
tank pad. The tank pad usually has three 10,000-gallon underground storage
tanks and is about 40' by 30'. Leaks usually occur at the dispensers,
interconnecting piping, tank fill pits and the actual tank walls. Using the
tank pad area and the dispensers in the pump islands as a focal point, a
leaking underground storage tank system would thus have a circular areal zone
of contamination with a diameter of 100'. Assuming a vadose zone of 10' and a
saturated zone of 10' and a porosity of 20%, the vadose air volume that would
have to vacuum extracted and treated would be about 15,700 cubic feet and the
saturated zone water volume to be extracted and treated would be about 117,400
gallons. Thus a system that has vapor phase capacity of 100 cfm and a liquid
phase capacity of 2 gpm will have the capability of extracting the vapor in
about 8 hours and the groundwater in about a month. Thus operating the system
for a few months will give several times of cleanup cycles of the vadose and
saturated zone contaminants - a concept that has been accepted by many
regulatory agencies and used in the treatment of numerous contaminated sites.
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Typical Cleanup System
An array of sparge wells and
vacuum extraction often adequately cleans up most petroleum contaminated sites.
OHC has researched the dynamics of vadose and saturated zone contamination and
the various remediation approaches than can be used to effect cleanup. We
realized early on that using conventional pump and treat systems with
activated carbon drums, air stripping towers and the like simply lead to long
treatment times, an unwieldy assortment of equipment that is hard to maintain
and enormous expenditure in time and money to the client. After considerable
modeling of groundwater and vadose zone, vapor extraction with average
transmissivity, porosity and other parameters that prevail over most of
Florida, we realized that sparging the saturated zone and driving the
contaminants into the upper vadose zone and then extracting them via a
powerful soil vapor extraction unit was the key to effectively and
economically achieve cleanup objectives. Incorporating a catalytic thermal
destruction unit, with a fair amount of overcapacity, completed the total
operational flexibility of the system. Adding the possibility of using
nitrogen and or hot exhaust from the catalytic unit ensured even more
effectiveness as it then could address iron fouling which is endemic in
Floridian groundwater due to the high iron and mineral content. For typical
gas station sites, three of these wells, with a cone of influence of about 30
feet will optimally cleanup the contaminated area in less time, with less
expenditures, and without the need to purchase or lease long term equipment
that is large, expensive, obtrusive and very difficult to maintain.
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Tank Closure Removal & Installation
Stringent underground and
aboveground tank compliance rules protect the environment and have enforceable
deadlines.
OHC is very cognizant of the amendments to the storage tank rules by the FDEP
over the past few years. These rule changes have mandated staggered deadlines
for both the underground and aboveground petroleum storage tanks in terms of
upgrades of the tanks themselves and also interconnecting piping and other
appurtenances. For instance, FAC 62-761.510 stipulates that by the end of 1998
all existing underground storage tank facilities should have secondary
containment, automatic line leak detection, overfill protection and liners for
the dispensers. OHC staff have worked on a number of tank removal and upgrade
projects to ensure storage tank system compliance with the regulations.
Tank removals are, in most cases, surprises in terms of the size of the tank
thought to be present underground. This arises mainly from the fact that most
of the tanks removals are discovered during site clearance and renovation work
and no records or regulatory information exists regarding these tanks - they
are very old unregistered tanks about which no information is available.
Another factor is that, when records are sketchy, the size of the tanks are
often underestimated and a suspected 500 gallon used oil tank turns out to be
a 1,000 or 2,000 gallon tank. Not only does this change the excavation and
removal scope in terms of time and cost, but often the residual oily liquid
than needs to be pumped changes quite considerably in volume, adding to the
cost. OHC has worked on numerous such projects with reputable tank removal
contractors and has a good working relationship to minimize these type of
unforeseen contingency costs and times. Again, in some cases, field
considerations may dictate that the tank be not removed but closed in place.
OHC often recommends such alternatives if it is in the best interest of the
client, which, in this case, will be the Manatee County Government.
Tank closure requirements have been revised as of June 1997 by the FDEP. The
Storage Tank Regulation Section in the Bureau of Waste Management has provided
guidelines to meet the FAC 62-761 requirements. These guidelines provide
detailed requirements for the sampling of soil and groundwater, the various
EPA test methodologies, sampling intervals and closure report requirements.
OHC's Project Manager, Engineer and Geologist have completed numerous tank
closures and are conversant will all the detailed requirements to ensure that
tank closures are complete and accepted by the FDEP and any relevant locally
contracted county program. An instance of these new guideline requirement is
sampling of associated piping and dispensers. Soil samples are required every
20 feet of product transfer line, two feet below the line level or immediately
above the groundwater table if it is shallower. As groundwater samples at
these locations will be at the discretion of the FDEP or local program, OHC's
Project Engineer will coordinate this with the appropriate liaison person to
ensure that the guidelines are followed. OHC's Project Manager will often
contact the liaison person ahead of the tank closure work schedule to allow
for these type of requirements. OHC's Project Engineer will make sure that
tank closure assessment form and report is submitted to the FDEP District
Office as soon as the tank closure work is completed, well ahead of the sixty
day window allowed by the FDEP and will follow up and expedite any additional
work necessary with the FDEP so that the client will receive a satisfactory
closure letter from the FDEP.
OHC firmly believes that contamination assessment is the backbone of the
entire site remediation phase of cleanup. At the expense of sounding like a
cliché, all the most expensive and efficient remediation technology will not
serve any purpose if it is deployed in the wrong place and in the wrong way
due to an inaccurate and or inadequate assessment. OHC's Project Geologist has
much experience with respect to petroleum and hazardous waste contamination
assessment. He will ensure that the FDEP and local program requirements for
contamination assessment are followed so as to obtain CAR approvals which are
vital in the sequence of steps in the cleanup of contaminated sites. Adequate
contact and liaison with the FDEP and local program staff will be maintained
to allow the review and approval of assessment plans. OHC realizes the
importance of obtaining the comments and incorporating the requirements of
FDEP and local program engineers and specialists. Communication with these
personnel early in the project often provides for a timely review and approval
of contamination assessment plans.
OHC is aware of the important role contamination assessment plays in the
rehabilitation of petroleum contaminated sites. Contamination assessment
defines and delineates the various contaminant chemicals and provides the
basis of the remedial action methodology that follows. Items such as site
history, geology an hydrology need to be accomplished in meticulous manner to
allow a good engineering remedial plan that will cost effectively and
efficaciously solve the contamination problem. The number and placement of
deep an shallow wells will determine the horizontal and vertical extent of
contamination. OHC's Project Geologist is very experienced in the design and
specification of monitor wells and the management of the drilling and
installation. OHC will judiciously request soil and groundwater test
parameters to ensure that the resultant CAR will satisfy the FDEP and local
program requirements. Close and effective liaison with the local program staff
often ensures prompt approvals of contamination assessment plans and reports
which will help in speedy remediation of contaminated sites.
OHC will complete contamination assessments for the Manatee County Government
following the new ASTM E 1903-97 guidelines for Phase II Environmental Site
Assessments. These newly released guidelines provide procedures for the
selection and use of drilling and soil sampling techniques, classifying and
describing soils, design of monitor wells and sampling and monitoring
groundwater using direct-push equipment. OHC realizes that not only does the
use of prescribed methods provide a proper evaluation of the presence or
absence of environmental contamination but also contributes to quick
regulatory review and approvals.
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Other Rehabilitation
Hazardous material spills,
releases and the discovery of abandoned, buried drums require immediate and
cautious response.
The release and spill of hazardous chemicals, such as mercury, sulfuric acid
and chlorine, pose a health risk to any workers in the immediate vicinity and
possibly to the public in the general vicinity depending upon the amount and
severity involved. OHC staff have responded to mercury and petroleum release
situations and have effectively contained and dealt with such incidences.
OHC's Project Manager and Engineer will ensure that the proper steps are taken
in these instances to protect the public and any workers involved from
immediate danger and then manage the effective cleanup of spill or release.
OHC staff are well versed in the various containment methods used in
petroleum, acid and other hazardous material release situations. A project
specific safety plan will be established and followed to ensure that the
cleanup crew are adequately protected from the hazardous materials than are
been dealt with. OHC will pay particular attention to the effectiveness of the
decontamination area and the proper temporary storage of hazardous materials
prior to removal and disposal. OHC will also ensure that all necessary
pre-burn tests and chain of custody, manifests etc. are meticulously completed
to allow report acceptance and closure with the FDEP and any other local
program. All OSHA requirements will be adhered to when completing hazardous
material removal work.
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