Contaminated Site Risk Based Corrective Action (RBCA) Flow Process Chapter 62-780, F.A.C.

Risk Management Options - Level I Discovery of Contamination

FP, saturated soil (petroleum), contaminated soil, or contaminated sediment documented

YES

Initial source removal feasible or cost-effective without a RAP

YES

Initial source removal implemented

See Level II Flow Chart

NO Assessment completed NO YES Does the site qualify for NFA without controls
Does the property owner elect to implement institutional and, if appropriate, engineering controls

YES

YES

NO

Criteria provided for each medium: Soil

Human Health/Direct Exposure
Note: The 95% UCL may be used for comparison to the CTLs provided the CTLs are apportioned.

NO

Groundwater
Options IA 1. COCs < Applicable default CTLs: GW and, if applicable, FSW or MSW from Table I (applicability based on the impact or potential impact to FSW or MSW), 2. COCs < Background, or 3. COCs < Best achievable detection limits

YES

Options IA 1. COCs < Residential CTLs (Table II), 2. 95% UCL of the COCs < Apportioned residential CTLs, 3. COCs < Background, or 4. COCs < Best achievable detection limits Option IB COCs < Apportioned alternative residential CTLs calculated using site-specific soil properties (Figs. 4-7 and Table VI) Option IC TRPH levels < Residential CTLs for the TRPH Leachability fractions provided in App. C Options IA 1. COCs < Applicable default leachability-based soil CTLs (Table II) based on applicable GW Option IA 1 CTLs, 2. COCs < Background, or 3. COCs < Best achievable detection limits Option IB COCs < Alternative leachability-based soil CTLs calculated (Fig. 8) using applicable Level I GW Option IA 2 Option IC Direct leachate results (SPLP/TCLP) < applicable Level I GW Options IA CTLs (Table I) Option ID COCs < Alternative applicable leachability-based soil CTLs calculated (Fig. 8) using site-specific soil properties Option IE TRPH levels < Leachability-based soil CTLs for the TRPH fractions provided in App. C

NAM Plan or NAM Extension to achieve NFA without controls

RAP or RAP Modification to achieve NFA without controls YES

Surface Water
Options IA 1. COCs < Applicable FSW or MSW CTLs (Table I), 2. COCs < Background, or 3. COCs < Best achievable detection limits A minimum of 2 sampling events is required for NAM that follows SA

NO

Free Product
Option IA Free product does not exist

A minimum of 4 sampling events is required for PARM and for NAM that follows AR. However, if contamination was only present in the unsaturated zone, only 1 sampling event is required

Sediment
Option IA 1. Contaminated sediment is not present, or 2. COCs < Background
Is a RAP Modif. or MOP Extension a cost-effective means to achieve Level I closure

Was the AR or NAM successful

NO

NO YES

Assessment needed due to additional contamination discovered

No Further Action without Controls

Definitions Apportioned: The adjustment of CTLs such that for non-carcinogen contaminants that affect the same target organ(s), the hazard index is 1 or less, and for carcinogens, the cumulative lifetime excess cancer risk is 1.0 E-6; AR: Active Remediation; COCs: Contaminants of Concern; CTLs: Cleanup Target Levels; FP: Free Product; FSW: Freshwater Surface Water; GW: Groundwater; MSW: Marine Surface Water; NAM: Natural Attenuation with Monitoring; NFA: No Further Action; PARM: Post Active Remediation Monitoring; RAP: Remedial Action Plan; SA: Site Assessment; SPLP: Synthetic Precipitation Leaching Procedure; TCLP: Toxicity Characteristic Leaching Procedure. TRPHs : Total Recoverable Petroleum Hydrocarbons. UCL: Upper Confidence Limit of the arithmetic mean. Note 1: Best achievable detection limit shall be the practical quantitation limit (PQL). Note 2: Figures 1, 2, 3A, 4, 5, 6, 7, and 8, and Tables I, II, and VI are provided in Chapter 62-777, FAC. Appendix C is provided in the technical report. Note 3: Flow Process provided to assist in understanding the RBCA flow process. Chapter 62-780, FAC, shall be utilized for final interpretation of the rule and requirements.

Contaminated Site Risk Based Corrective Action (RBCA) Flow Process Chapter 62-780, F.A.C. Risk Management Options - Level II
Does the site qualify for NFA with controls without a Risk Assessment See Level I Flow Chart Discovery

From Level I Flow Chart

NO

Criteria provided for each medium: Soil

Human Health/Direct Exposure
Note: The 95% UCL may be used for comparison to the CTLs provided the CTLs are apportioned.

Groundwater
Option IIA COCs < GW of low yield/poor quality CTLs (Table I), provided the following criteria are met:

Is AR or NAM a cost-effective means to achieve Level II closure

NO

See NFA with Controls utilizing risk assessment (Level III)

YES

Option IIA 1. Aquifer is of low yield, or poor quality, COCs < Commercial/industrial CTLs (Table II) 2. No actual impact or potential impact to Option IIB surface water (the more stringent of GW COCs > Level I residential CTLs (Table II), or FSW Level I CTLs) , and provided: engineering controls such as cover 3. Demonstration (minimum 1 year of material (minimum 2 feet of clean soil, c o n c r eGWe monitoring) that contaminant t pad, etc.) are used to prevent or manage human concentrations in GW at the property exposure boundaries will not exceed the applicable Option IIC Level I CTLs COCs < Apportioned alternative commercial/ industrial CTLs calculated using site-specific soil Option IIB properties (Figs. 4-7 and Table VI) COCs > Applicable CTLs provided Option IID engineering controls such as a TRPH levels < TRPH commercial/industrial permanent containment (e.g., slurry wall) CTLs for the TRPH fractions provided in App. C are used to prevent off-site contaminant migration (minimum 1 year of GW monitoring) and no impact or potential Leachability impact to surface water (the more stringent of GW, FSW, or MSW Level I Option IIA CTLs) COCs < Alternative leachability-based soil CTLs calculated (Fig. 8) using applicable Level Option IIC II GW CTLs COCs > GW or FSW CTLs (Table I), and Option IIB COCs < MSW CTLs (Table I) provided: Direct leachate results (SPLP/TCLP) < contamination is affecting or may applicable Level II GW CTLs potentially affect only a MSW body, and Option IIC there are no other properties or FSW COCs > Level I leachability-based soil CTLs bodies located between the source (Table II), provided: engineering control such as property and the MSW body impermeable cover is used to prevent infiltration (minimum 1 year of GW monitoring) Option IID Option IID COCs > Applicable groundwater CTLs, COCs < Alternative leachability-based soil provided the following are met: CTLs calculated (Fig. 8) using site-specific soil 1. Demonstration (historical data or properties and the applicable Level II GW CTLs modeling results) that contaminant Option IIE concentrations in GW at the property TRPH levels < Alternative leachability-based soil boundaries will not exceed the applicable CTLs for the TRPH fractions calculated using Level I CTLs, Fig. 8, the chemical/physical properties provided in App. C and the applicable TRPH Level II GW 2. Contamination is limited to the source CTL area (contamination < 1/4 acre) and is not Option IIF migrating from the localized source area Demonstration (minimum 1 year of GW (minimum 1 year of GW monitoring), and monitoring) that COCs based on site-specific conditions will not leach at levels > applicable 3. No impact or potential impact to on-site Level I or Level II GW CTLs FSW or MSW (the more stringent of GW, FSW, or MSW Level I CTLs)

NAM Plan or NAM Extension to achieve NFA with controls based on default Level II options

RAP or RAP Modification to achieve NFA with controls based on default Level II options

YES NO

YES

A minimum of 4 sampling events is required for alternative CTLs. However, if contamination was only present in the unsaturated zone, only 1 sampling event is required

Is a RAP Modif. or NAM Extension a cost-effective means to achieve Level II closure

Was the AR or NAM successful

NO

NO

Assessment needed due to additional contamination discovered

YES
Was an engineering control selected and approved YES

NO

Free Product
Option IIA FP may remain within the property boundary provided: 1. Source removal is not feasible, and 2. Institutional controls and, if required, engineering controls are used to protect human health, public safety, and the environment

Was the eng. control successful based on verification period, if warranted

Options available: 1. Repair or Modification 2. NAM or AR 3. Reevaluation of closure options

NO YES

Implementation of institutional controls

No Further Action with Controls

Definitions Apportioned: The adjustment of CTLs such that for non-carcinogenic contaminants that affect the same target organ(s), the hazard index is 1 or less, and for carcinogens, the cumulative lifetime excess cancer risk is 1.0 E-6; COCs: Contaminants of Concern; AR: Active Remediation; CTLs: Cleanup Target Levels; FP: Free Product; FSW: Freshwater Surface Water; GW: Groundwater; Low Yield: Aquifer that has an average hydraulic conductivity of less that 1 ft/day and a maximum yield of 80 gals/day; MSW: Marine Surface Water; NAM: Natural Attenuation with Monitoring; NFA: No Further Action; Poor Quality: Affected groundwater with background concentrations that exceed any of Florida's Primary or Secondary Drinking Water Stds; RAP: Remedial Action Plan; SPLP: Synthetic Precipitation Leaching Procedure; TCLP: Toxicity Characteristic Leaching Procedure. TRPHs: Total Recoverable Petroleum Hydrocarbons. UCL: Upper Confidence Limit of the arithmetic mean. Note 1: Figures 1, 2, 3A, 4, 5, 6, 7, and 8, and Tables I, II, and VI are provided in Chapter 62-777, FAC. Appendix C is provided in the technical report. Note 2: Flow Process provided to assist in understanding the RBCA flow process. Chapter 62-780, FAC, shall be utilized for final interpretation of the rule and requirements.

Contaminated Site Risk Based Corrective Action (RBCA) Flow Process Chapter 62-780, F.A.C. Risk Management Options - Level III

From Level II Flow Chart

Does the site qualify for NFA with controls utilizing a Risk Assessment

A reevaluation of the options to achieve NFA with or without controls (Level I, II, or III)

See Level I Flow Chart Discovery

Criteria provided for each medium: Soil

Human Health/Direct Exposure Option IIIA
Note: The 95% UCL may be used for comparison to the CTLs.

Groundwater

NO

Option IIIA COCs < Apportioned alternative CTLs based on a site-specific risk assessment Leachability Option IIIA COCs < Alternative leachability-based soil CTLs calculated (Fig. 8) using applicable Level III GW CTLs Option IIIB Direct leachate results (SPLP/TCLP) < Applicable Level III GW CTLs Option IIIC COCs > Level I leachability-based soil CTLs (Table II) provided: engineering controls such as impermeable cover is used to prevent infiltration (minimum 1 year GW monitoring) Option IIID COCs < Alternative leachability-based soil CTLs calculated (Fig. 8) using site-specific soil properties and the applicable Level III GW CTLs Option IIIE TRPH levels < Alternative leachability-based soil CTLs for the TRPH fractions calculated using Fig. 8, the chemical/physical properties provided by Appendix C and applicable TRPH Level III GW CTLs Option IIIF Demonstration (minimum 1 year of GW monitoring) that COCs based on site-specific conditions will not leach at levels > applicable Level III GW CTLs

COCs < Apportioned alternative CTLs based on a site-specific risk assessment, and Demonstration (minimum 1 year of GW monitoring) that GW concentrations at the institutional control boundary do not and will not exceed applicable Level I CTLs (GW Options IA and, if applicable, surface water Options IA) and no impact or potential impact to surface water (the more stringent of GW, FSW, or MSW Level I CTLs) NO

NAM Plan or NAM Extension to achieve NFA with controls based on site-specific risk assessment (alternative CTLs)

RAP or RAP Modification to achieve NFA with controls based on site-specific risk assessment (alternative CTLs)

YES

Free Product
Option IIIA FP may remain within the property boundary provided: 1. Source removal is not feasible, and 2. Institutional controls and, if required, engineering controls are used to protect human health, public safety, and the environment

YES

A minimum of 4 sampling events is required for alternative CTLs. However, if contamination was only present in the unsaturated zone, only 1 sampling event is required

Is a RAP Modif. or NAM Extension a costeffective means to achieve Level III closure

Was the AR or NAM successful

NO

YES NO
Options available: 1. Repair or Modification 2.NAM or AR 3. Reevaluation of closure options Was the eng. control successful based on verification period, if warranted Was an engineering control selected and approved

Assessment needed due to additional contamination discovered

NO

YES

YES

NO

Implementation of institutional controls

No Further Action with Controls

Definitions Apportioned: The adjustment of CTLs such that for non-carcinogenic contaminants that affect the same target organ(s), the hazard index is 1 or less, and for carcinogens, the cumulative lifetime excess cancer risk is 1.0 E-6; AR: Active Remediation; COCs: Contaminants of Concern; CTLs: Cleanup Target Levels; FP: Free Product; FSW: Freshwater Surface Water; GW: Groundwater; MSW: Marine Surface Water; NAM: Natural Attenuation with Monitoring; NFA: No Further Action; RAP: Remedial Action Plan; SPLP: Synthetic Precipitation Leaching Procedure; TCLP: Toxicity Characteristic Leaching Procedure. TRPHs: Total Recoverable Petroleum Hydrocarbons. UCL: Upper Confidence Limit of the arithmetic mean. Note 1: Figures 1, 2, 3A, 4, 5, 6, 7, and 8, and Tables I, II, and VI are provided in Chapter 62-777, FAC. Appendix C is provided in the technical report. Note 2: Flow Process provided to assist in understanding the RBCA flow process. Chapter 62-780, FAC, shall be utilized for final interpretation of the rule and requirements.