Background:
Support by management within the Florida Department of Environmental Protection (FDEP) to participate in the ITRC is allowing a faster spreading and understanding of knowledge and experience from ITRC State Regulators, Federal Agencies, Corporations, and Private stakeholders, as well as consultants and technology promoters. Experience gained by FDEP personnel from participation in the ITRC has created opportunities to promote or open up regulators, regulated parties, and the remediation industry to allow consideration and use of ITRC products within Florida. The following examples are intended to highlight some events that have taken place in the State of Florida where use of ITRC products and related expertise have promoted the acceptance and use of innovative technologies or have identified and reduced barriers that inhibit the acceptance of these innovative technologies.

Accelerated Site Characterization Technology:
One major Geotechnical & Engineering Firm in Florida primarily working on petroleum sites talked about their technology with Tom Douglas, an engineer in the Technical Review Section of FDEP's Division of Waste Management /Bureau of Waste Cleanup. The proposed use of their direct push (induced fluorescence) geologic screening technology was rapidly evaluated and recommended for use to screen a Florida Manufactured Gas Plant site. These events occurred during the last quarter of 1997. Issues relating to the assessment and remediation of this site still were unresolved. Complications relating to the remediation of "petroleum" and non-petroleum contamination cost were also an issue. Reimbursement for petroleum related costs were being sought from the FEDEP's Petroleum Cleanup Program. Tom Douglas's involvement and the understanding he gained from dealing with the Laser Induced Fluorescence ITRC documents allowed him to comfortably recommend useing the proposed direct push/induced fluorescence/geo-logging system, to delineate MGP and petroleum plumes. The screening information provided by this technology can rapidly enable the Department, responsible parties, and the consultant to improve the vertical and horizontal delineation of petroleum and MGP contaminants in the subsurface. FDEP's rapid acceptance and recommended use of this technology may have saved months in dealing with professional differences and uncertainties related to characterization at this site. In addition, this effort may help identify or eliminate questions concerning contaminant migration mechanisms. Allowing this technology to be used may also better indicate what (if any) remedial alternative(s) are acceptable and reasonable for dealing with on-site and off-site contamination. Savings in time for staff review, consultant's design, and legal representation can be expected to be substantial.

Use of induced fluorescence/geologic mapping screening tools at non-petroleum, petroleum, and potentially chlorinated sites (in the near future) can be expected to become a standard practice for rapid site characterization, screening and geologic mapping. The ITRC documentation for this technology along with the related network of experienced technical and regulatory personnel from other states has materially helped FDEP in applying this technology in Florida. Specifically, the "ITRC/ASTM Partnership for Accelerated Site Characterization,"/"Multi-State Evaluation of Expedited Site Characterization Technology, Site Characterization and Analysis Penetrometer System Laser-Induced Fluorescence (SCAPS-LIF) - May 1996", and the "ITRC/ASTM Partnership for Accelerated Site Characterization" documents were used to improve communication, knowledge and acceptance.

Natural Attenuation
The ITRC guidance documents and related network of contacts (including environmental personnel from the Environmental Protection Agency, Department of Defense, Department of Energy, and others) have provided the prerequisite foundation for FDEP to recommend studying natural attenuation at an NPL site contaminated with petroleum products and chlorinated solvents in the Tampa area. The ITRC participation allowed FDEP staff a much higher level of comfort in considering new technology opportunities for reaching Florida's cleanup goals. Estimated time savings in the last year are between 20 and 40 hours for one engineer working on the Tampa NPL project (Tom Douglas). In addition other staff time from FDEP, EPA, and the consulting firm have likely been reduced by possibly dozens of hours. The time saved is now being directed at identifying natural attenuation concerns and developing a better monitoring program. Also, cost savings associated with reduced monitoring and recovery well sampling, the temporary shut down of the groundwater treatment system, and potential natural degradation of groundwater contaminants may be large enough to cover the cost of the "Natural Attenuation" study. Information gathered on this project may also provide reasonable assurance to use Natural Attenuation at many other sites with similar contaminants and geologic conditions in this region of the state. The following ITRC documents were used: "ISB Protocol Binder and Resource Document for Hydrocarbons (1996)," "Natural Attenuation of Chlorinated Solvents in Groundwater-Principles and Practices-DRAFT MATERIALS", "Regulatory Guidelines for Permeable Barriers Designed to Remediate Chlorinated Solvents-DRAFT MATERIALS", and the "Design Guidance for Application of Permeable Barriers to Remediate Dissolved Chlorinated Solvents-DRAFT MATERIALS".

In Situ Bioremediation
ITRC involvement improved the level of comfort for one FDEP engineer (Douglas) sufficiently for him to promote and recommend augmented bioremediation at a chlorinated solvent site in Miami. Savings of about 50 to 100 hours of professional regulatory staff time (County, District, Tallahassee) were achieved. The ITRC's In-Situ Bioremediation reports and drafts were used in the review of this site and the recommendation to consider use of "In Situ Bioremediation" technologies at a chlorinated solvent site.

Metals in Soils

1. FDEP technical staff used ITRC guidance documents to explain, promote and recommend alternatives at a Lead Acid Battery site in Tampa. The documents provided coworkers with a better level of understanding and level of comfort. It was also helpful to demonstrate to technical staff that regulators across the country are facing similar difficulties when dealing with metals in soil or groundwater. This helped technical staff and could assist the District Office when dealing with enforcement or assessment issues. Such use could also encourage and promote remedial options that might be more reliable, implemented quicker, and reduce costs while providing assurance that environmental contaminants will be thoroughly addressed. Time savings are estimated at 20-30 hours so far on this ongoing effort. ITRC's In-Situ Bioremediation, Metals in Soils, and Permeable Barrier Walls documents and references were used.
2. In a situation similar to the Lead Acid Battery site in Tampa, ITRC products and related exposure to information about innovative technologies helped FDEP technical staff identify regulatory concerns and potential technical possibilities for the remediation of metals in the soil and groundwater in a battery waste NPL site in North Florida. Estimated savings for one engineer (Douglas) have been approximately 10-20 hours, so far.

Low Temperature Thermal Desorption (LTTD)
Tom Douglas, FDEP engineer, was able to recommend and use the ITRC thermal desorption references during a 10% bid design meeting with the Army Corps of Engineers at a Jacksonville NPL site. This greatly improved Mr. Douglas's comfort and confidence during the discussions with City, County, State, and Federal participants. The Army Corps of Engineers had already identified concerns listed in the ITRC protocols and was prepared to deal with the regulatory and safety issues. In addition, the Corps was prepared to deal and cover issues related to local residents and potentially sensitive public relation issues before they become a problem. Tom Douglas states that he was much more comfortable in directing issues relating to air emissions and standards to the Department's Air Resources Division that had to be agreed upon before the bidding design document could be moved forward. Time savings estimated at 10 to 20 hours for his efforts alone.

Institutional Change

1. New ways are being attempted to connect FDEP staff and other parties to the ITRC Web Site, which provides direct access to and download capability for all the ITRC technical guidance documents, case studies and technology assessments. Whenever possible, ITRC products are being recommended for use to vendors, consultants and interested parties. These efforts should help identify regulatory concerns and improve acceptance, approval, and use of better technologies where appropriate. It is also expected that this FDEP effort will result in better technical presentations and documents being submitted to the Department, which will allow the technical staff to understand and deal with the increasing technical demands more efficiently and effectively.
2. Use of the ITRC documents as technical reference is being promoted during the development of a FDEP rule for the treatment of contaminated soils at fixed treatment facilities. The rulemaking effort will expand the current regulation under the Department's Solid Waste Section. It is believed that once a mechanism is in place to allow the permitting of "Fixed Soil Treatment Facilities" viable emerging technologies will be built to remediate soils throughout the state. Tom Douglas has used all of the ITRC resources to promote the concept of permitting "Fixed Soil Treatment Facilities" of more than just thermal treatment of petroleum contaminated soils. Participation with the ITRC provided Douglas with technical information and confidence to move forward with this concept. In his view, the ITRC documents appear to be the best technical protocols for regulators and technology advocates -- they create a method to professionally deal with regulatory concerns and the need for "Reasonable Assurance" to protect public and the environment. Best estimate is that between 40 to 100 hours have been saved so far in this rulemaking development process.
3. Tom Douglas has proposed that FDEP's Division of State Lands get involved with the EPA's SITE Demonstration program. Such involvement or benefits from such an effort will hopefully lead to the rapid, effective, and cheaper acceptance of innovative technologies over the next few years.
4. Tom Douglas worked with, promoted, and recommended a treatment study for the Low Pressure/Low Temperature Thermal desorption of a state site with soil highly contaminated with toxaphene (and other pesticides). Additionally, Bio-remediation studies for both this pesticide site and a Manufactured Gas Plant state site were recommended. Participation with the ITRC encouraged him to follow through on this effort. In addition, he has communicated with several other professionals within FDEP and is attempting to identify where and how effectively technologies covered by the ITRC are being used or considered. Attempts to use or recommend uses of ITRC documents are also being pursued. Examples of such sites include but are not limited to:
   • Potential use of permeable barrier walls at Dry Cleaner sites under the FDEP's "Dry Cleaning Program" where current remedial options are cost prohibitive or currently considered technically impractical.
   • Implementation and study of Permeable Barrier Walls by the Department of Defense (DOD) at Cape Canaveral.
   • Study of Bio-Remediation and Natural Attenuation at a site within the at the DOE's Pinellas Remediation site.

What are the overall benefits of Florida's use of ITRC Guidance Documents and implementation of institutional change?
The following observations relate primarily to the Florida Department of Environmental Protection, Division of Waste Management, Bureau of Waste Cleanup, Technical Review Section. According to Tom Douglas, his participation as Florida's State Point of Contact and as a Florida Department of Environmental Protection (FDEP) state regulator and engineer has provided him with a great professional opportunity.

"I have rapidly learned about promoting new and innovative uses of technologies and participated in the drafting of several protocols on thermal desorption. The ITRC has helped other County, State, Federal, interested parties and me to understand concerns of regulators. This allows us and the regulated community to deal with the complexities of promoting, permitting, and implementing innovative technologies to remediate hazardous contaminants. The emerging concepts and protocols developed by the ITRC help to bridge or at least identify technical and regulatory gaps. Further participation should enable Florida and the FDEP to: professionally promote innovation; deal with technical and regulatory issues; and most importantly promote faster, cheaper, and environmentally acceptable means of remediating contaminants to protect public health and safety and the environment.

" Identifying the successful use, distribution, and resulting changes in regulatory practices due to ITRC products currently is difficult to quantify. Resulting changes in practice may be a direct result of Florida's participation with the ITRC and/or they could be in combination (synergetic) with other events and technological advancements. However, change is occurring and use of ITRC documents and participation in the ITRC is providing benefit to the technical staff. Participation has also provided several regulators and technology advocates with a higher level of comfort to deal with many technologies currently considered new or innovative. It is my opinion, that any use of the ITRC products or subsequent institutional changes will improve acceptance of promising technologies and Florida can reap benefits well beyond the documented original acceptance and use of such technologies. We expect these new technologies will become standard remediation tools if allowed to be demonstrated and accepted where appropriate.

Who to Contact for Additional Information:
Mr. Thomas Douglas
Florida Department of Environmental Protection
2600 Blairstone Road (MS 4535)
Tallahassee, Florida 32399-2400
Phone: 850-487-3299
Fax: 850-922-4368
e-mail: douglas_t@dep.state.fl.us

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