Attachment 1 to SOW (1).pdf

1821 Sahlman Drive, Tampa Florida 33605, Tel 813 258-5561, Fax 813 258-4257 Tampa, FL ▪ Knoxville, TN ▪ Port Townsend, WA

November 23, 2015

Mr. Carl Heintz, P.G.

Senior Hydrologist

Environmental Protection Commission

Hillsborough County

3629 Queen Palm Drive

Tampa, Florida 33619

Source Assessment Report Addendum (SARA)

James A. Haley Veterans’ Hospital

Power Plant Compound

13000 Bruce B. Downs Boulevard

Tampa, Florida 33612

FDEP ID No. 29/8627247

Dear Mr. Heintz:

This Site Assessment Report Addendum (SARA) addresses EPCHC comments dated October

22, 2015 and included as Appendix A. Comments are addressed in the order received.

Comment 1

Please provide a copy of the certification of treatment for the 91.28 tons of petroleum-contaminated soil that were thermally treated, as required by Rule 62-780.500(7)(a)14, F.A.C.

Response 1

The certificate of treatment is included as Appendix B.

Comment 2

Please provide construction diagrams for recovery wells RW-1 through RW-5, as required by

Rule 62-780.600(8)(a)21, F.A.C.

Response 2

A total of eight (8) recovery wells (RW-1 thru RW-8) have been installed at the site. All recovery wells are constructed of schedule 40 PVC installed to a depth of 14 ft bls with well screens extending from 9 to 14 ft bls. Recovery wells RW-1 thru RW-5 are 2-inch diameter while recovery wells RW-6 thru RW-8 are 1-inch diameter. Recovery well locations are included on Figure 1. Recovery well construction diagrams are included in Figure 2.

Comment 3

Please provide a scaled site map that shows the estimated extent of free product, as required by

Rule 62-780.600(8)(a)25, F.A.C.

Response 3

A scaled site map illustrating the extent of free product is included as Figure 1.

Comment 4

The geologist of record concludes, “Although a slight BaP exceedance of the residential SCTL was detected in soil sample SB-21 obtained from 0-6 inches bls, this detection is an anomaly and consistent with background BaP concentrations in urban environments.” Please include the geologist of record’s conclusion as a footnote on all pertinent scaled site diagrams and analytical summary tables. This will be important at the time that you and your consultant propose closure for the above-referenced petroleum discharge.

Response 4

Acknowledged. This footnote will be added to all pertinent scaled site diagrams and analytical summary tables included in future submittals.

Comment 5

The geologist of record recommends continuing free product recovery and conducting quarterly groundwater monitoring of monitoring wells MW-3, MW-4, MW-5, MW-6, MW-7 and DW-1 for

BTEX/MTBE, PAHs and TRPH. Please include contaminated temporary monitoring locations

TMW-1 and TMW-2 (using 10 to 15 foot well screens, not 5 foot screens) as source well locations for groundwater monitoring and free product recovery. Also, if the low levels of petroleum contamination in apparent downgradient monitoring well MW-3 do not attenuate, please be advised that a monitoring well along the downgradient edge of the plume will need to be installed if a Remedial Action Plan (RAP), Natural Attenuation Monitoring (NAM) Plan and/or Post Active Remediation Monitoring (PARM) Plan are proposed in the future. Quarterly

Free Product Recovery Reports (including free product extent maps) should be submitted in accordance with the requirements of Rule 62-780.500(7), F.A.C.

Response 5

Acknowledged. Upon approval of the SARA, temporary monitoring wells TMW-1 and TMW-2 will be reinstalled using 10 to 15 foot wells screens. In the event the petroleum contamination in downgradient monitoring well does not attenuate, an additional well will be installed along the downgradient edge of the plume.

CONCLUSIONS AND RECOMMENDATIONS

The data contained is this SARA, along with the previous SAR, fulfill Site Assessment requirements in accordance with FAC 62-770. Streamline recommends completing the following activities:

• Conduct quarterly groundwater monitoring to help assess site closure options.

Groundwater samples should be collected from monitoring wells TMW-1, TMW-2, MW-

3, MW-4, MW-5, MW-6, MW-7, and

DW-1. The groundwater samples should be analyzed by EPA Methods 8260

(BTEX/MTBE), 8270 (PAHs), and TRPH by Method FL-PRO.

• Continue free product recovery until no free product remains.

• Prepare and submit quarterly groundwater monitoring and free product recovery reports to the EPC within 30 days of receipt of laboratory results. Reports will include summary tables and site plans summarizing the data. Groundwater flow direction will be determined during each monitoring event. Reports will include a discussion of results, contaminant trends, and free product extent maps.

• Determine if the site may meet the criteria for conditional site closure in accordance with

Chapter 62-780 – Risk Management Option Level II or Low Score Site Initiative No

Further Action pending site scoring.

Thank you for your attention to this matter. Please do not hesitate to contact me if you have any questions or need any additional information at this time. We look forward to your response.

Sincerely, STREAMLINE ENVIRONMENTAL, INC.

Lee T. Ford

Senior Environmental Scientist cc: Victoria Cockrell, James A. Haley Veterans’ Hospital

FIGURES

DATE: 11/20/15 FILE: 150106 BY: LTF

FIGURE 1

WELL LOCATION MAP

JAMES A. HALEY VETERANS’ HOSPITAL

13000 BRUCE B DOWNS BOULEVARD

TAMPA, FL 33612

APPROXIMATE SCALE

1 INCH = 10 FEET

0 10

CONCRETE DRIVEWAY

12,000 GAL.

DIESEL AST

12,000 GAL.

DIESEL AST

CONCRETE SLAB

CONCRETE SLAB

ESTIMATED

EXTENT OF

FREE PRODUCT

DISTRIBUTION

UNDERGROUND

DIESEL SUPPLY LINE

UNDERGROUND

DIESEL SUPPLY LINE

CONCRETE

WALKWAY

POWER PLANT

CONTROL ROOM

CONCRETE SLAB

CONCRETE SLAB

LOAD

BANK

LOAD

BANK

TRANSFORMERS

GRAVEL

CONCRETE SIDEWALK

GRAVEL

FILTER BOX

12 FT BLOCK WALL

ASPHALT DRIVEWAY

GRAVEL

G R

A V

E L

GRAVEL

GRAVEL

GRAVEL

MW-6

0.0

TMW-1

0.3

TMW-2

0.0

MW-3

0.0

MW-4

0.0

MW-5

0.0

MW-6

0.0

MW-7

0.0

DW-1

0.0

RW-1

0.0

RW-2

0.0

RW-3

1.1

RW-4

2.03

RW-5

0.3

RW-8

0.6

RW-3

0.3

RW-3

0.3

X

12,000 GAL.

DIESEL AST

RW-7

2.6

RW-6

6.1

LEGEND

= 2-INCH RECOVERY WELL LOCATION

= WELL DESIGNATION

= INCHES OF FREE PRODUCT

= 1-INCH RECOVERY WELL LOCATION (INACTIVE)

= MONITORING WELL LOCATION

= TEMPORARY WELL TMW-1 REMOVED AND WILL BE

REINSTALLED AT A LATER DATE

MW-5

0.0

X

DATE: 11/20/15 BY: LTFFILE: 150106

FIGURE 2

RECOVERY WELL CONSTRUCTION DIAGRAM

APPROXIMATE

PROPERTY BOUNDARY

LAND SURFACE

20/30 GRADE

SILICA SAND

FILTER PACK

WELL POINT

5 FEET

0.010 INCH - SLOTTED

WELL SCREEN

14 FEET BELOW

LAND SURFACE

APPROXIMATE

WATER TABLE

10 FT BLS

9 FEET

SOLID PVC

WELL CASING

(RW-1 THRU RW-5 = 2-INCH DIAMETER)

(RW-6 THRU RW-8 = 1-INCH DIAMETER)

NOT TO SCALE

JAMES A. HALEY VETERANS’ HOSPITAL

13000 BRUCE B DOWNS BOULEVARD

TAMPA, FL 33612

APPENDIX A

EPC COMMENT LETTER – OCTOBER 22, 2015

COMMISSION DIVISION DIRECTORS

Kevin Beckner Lesley “Les” Miller, Jr. Legal & Admin. Richard Tschantz, Esq.

Victor D. Crist Sandra L. Murman Air Management Jerry Campbell, P.E.

Ken Hagan Stacy White Waste Management Hooshang Boostani, P.E.

Al Higginbotham Water Management Sam Elrabi, P.E.

Wetlands Management Scott Emery, Ph.D.

EXECUTIVE DIRECTOR

Janet Dougherty

An agency with values of environmental stewardship, fairness, and cooperation Roger P. Stewart Center

3629 Queen Palm Drive, Tampa, FL 33619 - (813) 627-2600 - www.epchc.org An Affirmative Action / Equal Opportunity Employer

October 22, 2015

Ms. Victoria Cockrell

Veterans Administration Hospital

13000 Bruce B Downs Blvd.

Tampa, Florida 33612-4745

Dear Ms. Cockrell:

SUBJECT: JAMES A HALEY VETERANS HOSPITAL, 13000 BRUCE B DOWNS

BLVD, TAMPA, FLORIDA, FDEP FACILITY ID #298627247 –

PETROLEUM DISCHARGE DISCOVERED ON JANUARY 12, 2015

On October 21, 2015, Environmental Protection Commission (EPC) Petroleum Cleanup Section staff received Streamline Environmental, Inc.’s (Streamline) April 16, 2015 Interim Source

Removal Report (ISRR)/Site Assessment Report (SAR) that has been submitted in response to

EPC Storage Tanks Compliance Department (STCD) staff’s January 26, 2015 site assessment

(SA) initiation request letter to Veterans Administration Hospital. The ISRR/SAR helps to address the above-referenced diesel fuel discharge, which currently does not have an assigned score from the Florida Department of Environmental Protection (FDEP) Petroleum Restoration

Program (PRP).

The ISRR/SAR requires additional information. Pursuant to Rules 62-780.500(8) and 62-

780.600(10) of the Florida Administrative Code (F.A.C.), please provide two professionally certified copies of an ISRR/SAR Addendum (i.e., one hard copy and one electronic copy) that addresses the following comments within sixty (60) days of the date of this letter.

Please provide a copy of the certification of treatment for the 91.28 tons of petroleum-contaminated soil that were thermally treated, as required by Rule 62-780.500(7)(a)14, F.A.C.

Please provide construction diagrams for recovery wells RW-1 through RW-5, as required by Rule 62-780.600(8)(a)21, F.A.C.

Please provide a scaled site map that shows the estimated extent of free product, as required by Rule 62-780.600(8)(a)25, F.A.C.

The geologist of record concludes, “Although a slight BaP exceedance of the residential

SCTL was detected in soil sample SB-21 obtained from 0-6 inches bls, this detection is an anomaly and consistent with background BaP concentrations in urban environments.” Please include the geologist of record’s conclusion as a footnote on all pertinent scaled site diagrams and analytical summary tables. This will be important at

October 22, 2015

Ms. Cockrell the time that you and your consultant propose closure for the above-referenced petroleum discharge.

The geologist of record recommends continuing free product recovery and conducting quarterly groundwater monitoring of monitoring wells MW-3, MW-4, MW-5, MW-6, MW-7 and DW-1 for BTEX/MTBE, PAHs and TRPH. Please include contaminated temporary monitoring locations TMW-1 and TMW-2 (using 10 to 15 foot well screens, not 5 foot screens) as source well locations for groundwater monitoring and free product recovery. Also, if the low levels of petroleum contamination in apparent downgradient monitoring well MW-3 do not attenuate, please be advised that a monitoring well along the downgradient edge of the plume will need to be installed if a Remedial Action Plan

(RAP), Natural Attenuation Monitoring (NAM) Plan and/or Post Active Remediation

Monitoring (PARM) Plan are proposed in the future. Quarterly Free Product Recovery

Reports (including free product extent maps) should be submitted in accordance with the requirements of Rule 62-780.500(7), F.A.C.

Please call me at (813) 627-2600 ext. 1302 if you wish to discuss these matters. Please reference the FDEP Facility ID # if you call.

Sincerely, Carl J. Heintz, P.G.

Senior Hydrologist c: FDEP OCULUS

Steffanie Wickham, General Manager III, EPC Petroleum Cleanup Section

Craig R. Smith, P.G., Streamline Environmental, Inc., 1821 Sahlman Drive, Suite B, Tampa, Florida 33605

Brian Dinning, Project Manager, Streamline Environmental, Inc., 1821 Sahlman Drive, Suite B, Tampa, Florida 33605

Lee T. Ford, Streamline Environmental, Inc., 1821 Sahlman Drive, Suite B, Tampa, Florida 33605

Monthly Report File

FDEP Facility ID #298627247 File

APPENDIX B

CERTIFICATE OF TREATMENT