GROUNDWATER CONTAMINATION AT THE FLEET MAINTENANCE FACILITY
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INTERLOCAL AGREEMENT BETWEEN
THE STATE OF FLORIDA
DEPARTMENT OF ENVIRONMENTAL REGULATION
AND THE CITY OF CLEARWATER
OGC No. .90-1172
I);
THIS INTE~LOCAL :GREEMENT is made and entered into this
day of ~. 199/. by and between the STATE OF FLORIDA
DEPARTMENT OF ENVIRONMENTAL REGULATION (herein, the "Department"),
and the CITY OF CLEARWATER, FLORIDA, a Florida municipality located
in pinellas County, Florida (herein, the "City").
WHEREAS, the Department and the City have determined that
certain corrective actions may be necessary in order to eliminate
certain groundwater contamination which may be found to exist at the
fleet maintenance facility of the city, and that a preliminary
contamination assessment as described herein is the appropriate
first step in establishing the existence and the extent of any such
groundwater contamination at that location; and
WHEREAS, the Department is authorized to enter into agreements
with political subdivisions affected by the provisions of the
Florida Air and Water Pollution Control Act, Department rules and
policies. Section 403.061(21);
NOW, THEREFORE,
IN CONSIDERATION of the mutual covenants contained herein, the
parties hereto agree as follows:
1. The Department is the administrative agency of the state of
Florida having the power and duty to control and prohibit pollution
of air and water in accordance with Chapter 403, Florida Statutes,
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and rules promulgated thereunder in Florida Administrative Code
Title 17. The Department has jurisdiction over the matters
addressed in this Inte~local Agreement.
2. The City is a municipality and is a person within the
meaning of Section 403.031(5), Florida Statutes.
located in the City of Clearwater, Pinellas County, which is
3. The City owns certain real property (herein, the "Property")
described mOre particularly in Exhibit A to this Interlocal
Agreement. The Property was acquired by the city in February, 1988.
4. The City operates a fleet maintenance facility on the
property, and has operated the fleet maintenance facility on the
Property since May, 1988.
5. Groundwater sampling and analyses were conducted on the
property by the City in March 1990. The pertinent results of the
analyses include:
Monitor
Well #
Parameter
Concentration (uq/l)
Guidance
Concentrations (uq/l)
1
chromium
iron
iron
lead
oil & grease
80
3500
190,000
3,800
3,600
50*
300**
300
50*
2
3
4,4' DDE
4,4' DDT
chromium
iron
lead
0.016
0.075
110
32,000
30
50
300
50
22
chromium
iron
lead
360
330,000
6,900
50
300
50
tin
oil & grease
2,300
8,900
* primary drinking water standard
** secondary drinking standard
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",I". 6. Soil samp:\i1g and analyses were condu:::tfd on the property
by the city in March, 1990. The pertinent results of analyses
yielded these results:
Soil Borinq #
Parameter
Concentration (mq/ko)
1
chromium
iron
0.51
130
2
chromium
iron
lead
tin
oil & grease
38
72,000
5,800
510
91
3
chromium
iron
lead
2.1
210
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7. The City agrees to implement corrective actions as set
forth in the document entitled "Preliminary Contamination
Assessment Actions," attaChed hereto as Exhibit B, in the manner
and within the time frame set forth therein.
8. In the event the Preliminary Contamination Assessment
described in Exhibit B reveals the presence of contaminants in the
soil, sediment, surface water and/or groundwater in violation of .
water quality standards or minimum criteria, or reveals the
presence of contaminants which may reasonably be expected to cause
pollution of the surface and/or groundwater of the state in excess
of such standards or criteria, the City agrees to implement the
corrective actions set forth in the document entitled "Corrective
Actions For Ground Water Contamination Cases", attached as Exhibit
C, in the manner and within the time frames set forth therein.
[9. Within 30 days of execution of this Interlocal Agreement,
the City agrees to make payment to the Department for costs and
expenses in the amount of $250.00. Payment shall be made by
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certified check, cashiers check or money order to the "State of
Florida Department of Environmental Regulation." Payment,
specifying OGC Case #90-1172, shall be sent by certified mail to
the administrator, Division of Waste Management, Department of
Environmental Regulation, 4520 Oak Fair Boulevard, Tampa, Florida
33610-7347.
10. Within 20 days of execution of this Interlocal
Agreement, the city agrees to place warning signs at all areas
involved in this investigation. Warning signs shall be no smaller
than 2 sq. ft. legible, made of durable materials, located in
prominent locations around the areas of investigation at 100-foot
intervals, and read as follows: WARNING! NO TRESPASSING, WASTE
SITE STUDY AREA, AVOID CONTACT WITH SOIL AND WATER. FOR
INFORMATION (813) 623-556l.
11. With regard to any final agency action made by the
Department regarding the city's responses to the actions made
pursuant to this Interlocal Agreement, the City may file a
petition for formal or informal administrative proceeding, if the
City objects to the Department~s final agency action, pursuant to
Section 120.57, Florida Statutes, and Chapters 17-103 and 28~5,
Florida Administrative Code. The City shall have the burden to
establish the inappropriateness of the Department's final agency
action. The petition shall conform with the requirements of
Florida Administrative Code Rule 28-5.012, and shall be received
by the Department's Office of General Counsel, 2600 Blair Stone
Road, Tallahassee, Florida 32399-2400, within 21 days after
receipt of notice from the Department of any final agency action
the City wishes to challenge. Failure to file a petition within
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this time period shall constitute a waiver by the city of its
right to request an administrative proceeding under Section
120.57, Florida statutes. The Department's final agency action,
upon expiration of the 2l-day time period if no petition is filed,
or the Department's Final Order as a result of the filing of a
petition, shall be incorporated by reference into this Interlocal
Agreement and made part of it. All other aspects of this
Interlocal Agreement shall remain in full force and effect at all
times. If the city seeks an administrative proceeding pursuant to
this paragraph, the Department may file suit against the city in
lieu of or in addition to holding the administrative proceeding to
obtain judicial resolution of all the issues unresolved at the
time of the request for administrative proceeding.
12. Respondent shall publish the following notice in a
newspaper of general circulation in pinellas County, Florida. The
notice shall be published one time only within 14 days of the
effective date of this Interlocal Agreement by the Department.
Proof of publication shall be submitted to the Department within
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30 days of the effective date of this Interlocal Agreement.
state f Florida De artment of Environmental Re ulation
Notice of proposed AaenCY Action
The Department of Environmental Regulation gives notice
of agency action of entering into an Interlocal
Agreement with the City of Clearwater, Florida pursuant
to Florida Administrative Code Rule 17-103.110. The
Interlocal Agreement addresses the groundwater
investi at ions located in the cit f Clearwater 1 ln
inland bein- art of track "A" Re lat of Blocks 1 thru
19 of Marymont in pinellas County, Florida.
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The Interlocal Agreement is available for public
inspection during normal business hours, 8:00 a.m. to
5:00 p.m., Monday through Friday, except legal hOlidays,
at the Department of Environmental Regulation, Southwest
District, 4520 Oak Fair Boulevard, Tampa, Florida 33610.
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Persons whose substantial interests are affected by the
above proposed agency actions have a right to petition
for an administrative determination (hearing) on the
proposed action. The petition must conform to the
requirements of Chapters 17-103 and 28-5, Florida
Administrative Code, and must be filed (received) with
the Department's Office of General Counsel, 2600 Blair
Stone Road, Tallahassee, Florida 32399, within 21 days
of publication of this notice. Failure to file a
petition within the 21 days constitutes a waiver of any
right such person has to an administrative determination
(hearing) pursuant to Section 120.57, Florida Statutes.
If a petition is filed, the administrative hearing
process is designed to formulate agency action.
Accordingly, the Department's final action may be
different from the proposed agency action. Persons
whose substantial interests will be affected by any
decision of the Department have the right to intervene-
in the proceeding. A petition for intervention must be
filed pursuant to Model Rule 28-5.207, Florida
Administrative Code at least five (5) days before the
fin~l hearing and be filed with the Hearing Officer if
one has been assigned at the Division of Administrative
Hearings, 2009 Apalachee Parkway, Tallahassee, Florida
32399. If no Hearing Officer has been assigned, the
petition is to be filed with the Department's Office of
General Counsel, 2600 Blair Stone Road, Tallahassee,
Florida 32301. Failure to petition to intervene within
the allowed time frame constitutes a waiver of any right
such person has to an administrative determination
(hearing) under Section 120.57,Florida Statutes.
13. Nothing herein shall be construed to limit the
authority of the Department to undertake any action against
the City in response to, or to recover the costs of
responding to, conditions at or from the site which may
present an imminent hazard to the public health, welfare or
the environment if:
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A. The conditions were previously unknown to or
undetailed by the Department;
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B. The conditions result from the implementation of the
requirements of this Interlocal Agreement;
C. Other previously unknown facts arise or are
discovered after the entry of this Interlocal Agreement.
14. Entry of this Interlocal Agreement does not relieve
the City of the need to comply with all applicable federal,
s~ate and local laws, regulations and ordinances.
15. The terms and conditions set forth in this
Interlocal Agreement may be enforced in a court of competent
jurisdiction pursuant to Section 120.69 and 403.121, Florida
Statutes.
16. The City agrees to allow all authorized
representatives of the Department access to the Property at
reasonable times for the purpose of determining compliance
with the terms of this Interlocal Agreement and the rules of
the Department.
17. The Department hereby expressly reserves the right
to initiate appropriate legal action to prevent or prohibit
violations of applicable statutes or the rules promulgated
thereunder not covered by the terms of this Interlocal
Agreement.
18. This Inter10cal Agreement is not intended to affect
the Department's normal enforcement powers or
responsibilities, nor is this Interlocal Agreement a
Department enforcement action. However, it is the intention
of the parties that the course of action contemplated by this
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Interlocal Agreement shall constitute "corrective action" on
the part of the City for any groundwater contamination
violations that may have occurred in the past.
19. No modifications of the terms of this Interlocal
Agreement shall be effective unless and until reduced to
writing and executed by both the city and the Department.
20. Three copies of all reports, plans and data
required by this Interlocal Agreement shall be submitted to
the Department at the following address: Administrator,
Division of Waste Management, Southwest District, Department
of Environmental Regulation, 4520 Oak Fair Boulevard, Tampa,
Florida 33610-7347.
IN WITNESS WHEREOF, the partie.~ h n.eerreto
hands and seals, this ~ day of ~
have set their
, 199/.
CITY OF CLEARWATER, FLORIDA
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By:
Ri a Garvey
Mayor-Commissioner
Ron H.Rabun
City'" Ha,rtager'
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Approved as to form
and correctness:
Attest:
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hi'a ,F.:. Goud,e'd u:
',Clerk". "~'I"~
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M. A. GalbraiHl,
City Attorney
FILING A~~D ACKNOWLEDGEMENT
FILED, on this date, pursuant to 5120.52
::ior!C!Zl Slatutes, with the designated Depart.
ment Clerk, receipt of which is hereby acknow-
Ledged.
STATE OF FLORIDA DEPARTMENT
OF ENVIRONMENTAL REGULATION
:t1-d$ ~~,~
erk ,I.
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Date
Richard D. Ga rity, Ph.D.
Deputy Assis nt Secretary
Southwest D.strict
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, .Made tl/l~~----{;.61t:: cluyof January
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illrlmrrn JOHN H. HARLAND COMPANY,
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a corporation e.:r.i$ting u.n.du the laws of the State of Georgia, and
havint its priru;ipa.L place of bu.siness in the Cor.u~ty of Fu 1 ton
State of Georgia pa.rty of tlu jiNt pa.rt, a.n.d CITY OF
a Florida municipal corporation,
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DESCRIPTION ATTACHED AS EXHIBIT
SEE LEGAL
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SUBJECT to easements,
and real estate taxes
restrictions and reservations of record
for the year 1988 and Eubsequent years.
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~L~ ~~r~9f~res t ~mp~ovements on the subject lands are conveyeQ in "as
~~e wa~r~n~~~swol Ttti~l~~~t~ig~dw~~~:r~~es, expressed or impl~ed,except
.4.nd the sa;id pa,rty of the first pa..rt does hereby fu,Uy wa.rra..nt the title to sa.id La..n.d,
a..nd wiU Mfend the sa..rne a..,ga..inst the La,wfu.l claims of a..lL persol~s whomsoelJer.
. .... .
. ]1\ :mUnr.55 IDqPrFnf. the said pa.rty of the first part has
. ^ ~,'~ ,:~ :l:/ /.,. , . .' ccnued these pruents to be sitned in its name by its President.
'. ..' ~ .......:? .'. and,i~ corporate Ileal to be a:/fixed, attested by it,
" ,- the day a.nd year above written.
JOHN H. HARLAND COMPANY
.: (Corporate .,~;
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BY~~~; -
. Presiden.t.
.:4tte.st: :.. _ (. . I". .,
t;~~~. :>~atill ~nb Drliorrrb tn (eur
QLo<:\lk.; .A.. 4-..w-"d--
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t;..t -f_ f .7~L.--:.^- GEO J:..n=n f. De 01.""" \iltrk P;~~ln COunty
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3l llrrrby C!:rr1ify. Thot 01[ f his ~t. ~ day of January, ,1.. D. .1988 ,
before lIIe personally appe.a.red ~.e, u.J~ ~
'i-:-.-/ ~-: 0.-4/ ~c/ ~....... 7 President ~ t;--cI .5"<7<' o't'~~.
respectively of JOHN H. IliARLAND C0l-1PANY, ----------. , a corpo tiOIL
under ell('. I(lw~ of the State uf Georgia , to IIlfl /-:1l01(.'1~ to e the
pcrsOlls clescribed in alld u'ho e,l'ecutecl 0/(' forf!~()il/~ C'ollt'eyallce to'
CITY OF CLEAR\~ATER
alld severally ackllou'led~ed the e.l'C'C'utiOll thereof to be their free act and deed as
such olTicers, for the uses alld pllrpo.~es therein lIlentioned; alld that they atJixed
thereto the official scal of ~aid corporatioll, and the said instrronent is the act and
deed of SG,:a corporotiOlt,
milnr!l!l ,..n~$r~tj'(ro(' alld ofti cial seal at
ill the COUf'fjj~Cl~'R'~ 4~
Year last rU(ji "d, '. .N.... '.
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~ GEORGIA
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Ny' Commission Expires .11-.5., q ()
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That certain piece, parcel, or trlCt of land lying in and beio; part of Tract
"A", Replat of Blocks 1 thru 19 of Mar)'lllont, as recorded in Plat Book 39, page
31 of the Public Records of Pinellas County, Florida, lying in and being put
of the Northwest 1/4 of Section 12, Township 29 South, Range 15 East, Pinellas
County, Florida, and being more particularly described as follows:
Fran the intersection of the West right-of-way of Hercules Avenue and/or County
Road No. 34, a 100.0 foot right-of-way, with the North right-of-way of Grand
Avenue, a 60.0 foot right-of-way, North 89 deg. 20'05" West, and along said
North ri~ht-of-way, a distance of 450.0 feet for a P.D.B.; thence co.ntinue
North 89 deg. 20'05" I~st, and along said North ri;ht-of-way, It distance of
605.0 feet; thence North 00 c34-g. 17'00" East, a distance of 645.0 feet; thence
South 89 deg. 20'05" East, a distance of 275.0 feet to a point in the West
boundary of property conveyed to James T. Walker and Robert J. \';tlrd in o. R.
Book 4492, page 2131; thence South 00 deg. 17'00" West along said West
boundary, a distance of 230.0 feet to the Southwest corner thereof; thence
South 89~eg. 20'05" East along said South bouooary as extended East a distance
of 330.0 feet to the Northwest corner of property conveyeCI to Aerosonic
lnstrunent Corporation in Deed Book 1606, page 502; thence South 00 deg. 17 '00"
ivest along said l~st boundary, a d{stance of 415.0 feet to the North
ri~ht-of-way of said Grand Avenue and the P.D.B.
EXHIBIT ."A"
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PRELIMINARY CONTAMINATION ASSESSMENT ACTIONS
1. within 30 days of the effective date of the Order
incorporating these preliminary contamination assessment actions,
Respondent shall submit a Preliminary Contamination Assessment
Plan ("PCAP") to the Department. The PCAP shall describe the
tasks that Respondent proposes to perform 1n order to determine
whether the soil, sediment, surface water or ground water are
contaminated at Respondent'~ facility; and, if so, whether such
contamination has resulted in a violation of the water quality
standards and minimum criteria established in Florida
Administrative Code Chapter 17-3. The PCAP shall include a time
schedule for each task. so that all tasks can be completed and a
Preliminary Contamination Assessment Report ("PCAR") can be
submitted to the Department within 90 days of approval of the peAP
by the Department.
2. The PCAP shall include provisions [or the installation
and sampling of, in most cases, a minimum of four monitor wells to
determine the groundwater quality and flow direction at the site.
Proposal of fewer wells or an alternate well configuration is
subject to Department approval. Provision to sample surface
waters, sediments and soils shall be included as necessary.
A. One of the wells shall be located in the area
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suspected of greatest contamination and two wells shall be located
downgradient of the area suspected of highest cont~mination.
B. One of the \.;ells shall be an unaffected bac;>'Tound
well.
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C. The wells, surface waters, sediments and soils, as
applicable, shall be iampled and analyzed tor the following
paiameters with the listed method;
(1) priority pollutant metals using EPA Methods as
referenced in Table 18 of 40 CFR Part 136;
(2) priority pollutant organic chemicals using EPA
Methods 624 and 625;
(3) all non-priority pollutant organic chemicals
with peaks greater than 10 microgFams per liter (ug/l) using EPA
Methods 624 and 625;
(4) pesticides and herbicides using EPA Methods 608
and 625, if applicable, or other Department approved methods for
pesticides and herbicides for which 608 or 625 are not applicable;
and
(5) others, as applicable.
Proposal of-alternate analytical methods 1S subject to Department
approval. THe number of contaminants to be analyzed may be
reduced if Respondent can demonstrate to the Department's
satisfaction that the. contaminants proposed to b~ deleted from the
list cannot be attributed to any activities that have taken place
at Respondent's facility. The Department shall submit written
notification to the Respondent if the number can be reduced.
3. The PCAP shall include piovisions for investigation of
the folloy;ing conditions, as applicable, at the contamination site
and the area surrounding the contamination site:
A. The pr~sence and thickness of any free product at the
Revised/GW/PCAP/0188.2
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site;
B. The presence of soil contamination at the site;
C. The aquifers present beneath the site and their
Chapter 17-3, FAC, groundwater classification;
D. The number and locations of all public and private
potable supply wells within a 1/2 mile radius of the site;
E. The presence of surface waters of the state within a
1/2 mile radius of the site and, if applicable, their Chapter
17~3, FAC, classification; and
F. The geology and. hydrogeology of the site focusing on
aquifers and confining units which are present, the potential for
movement of contaminants both horizontally and vertically, zones
that are likely to be affe~ted, and actual and potential uses of
the groundwater as a resource.
4. The PCAP shall contain the following site specific
informational
A. Proposed well construction details including methods
and materials, well installation depths Dnd screened intervals and
well development procedures;
B. A description of methods and equipment to be used to
quantify soil contamination.
C. A descri~tion of water sampling methods, including
names of sampling personnel, procedures and equipment; and
D. Name of laboratory to be used for analytical work.
E. The parameters to be analyzed for, the ~nalytical
methods to used and the detection limits of these analytica1
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methods.
F. Site map depicting monitoring well locations and
other proposed sampling sites; and
G. A brief site history, and a description of facility
operations, as applicable.
5. The Department shall review the PCAP and provide
Respondent with a written response to the proposal. In the event
that additional information is necessary for the Department to
evaluate the PCAP, the Department shall make a written request to
Respondent for the information and Respondent shall provide the
requested information within 20 days from receipt of said
request. The PCAP shall incorporate all required modifications to
the PCAP identified by the Department. Any action taken by
Respondent with regard to the implementation of the PCAP prior to
the Respondent receiving written notification from the Department
that the PCAP has been approved shall be at Respondent's risk.
6. within (75) days of the Department's approval of the rCAP
(unless a written time extension is granted by the Department),
Respondent shall.submit a written Preliminary Contamination
Assessment Report ("PCAR") to the Department. The PCAR shall:
Jl.. summarize and analyze all "PCAP" tasks;
B. compare analytical data collecteo with sur~ace and
ground water quality standards and criteria set forth in Florida
Administrative Code Chapter 17-3. The following laboratory
quality assurance data shall be submitted along with the
analytical results;
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(1) the detection limits for these analyses;
(2) the results from the analyses of field blank and
duplicate samples;
(3) the results from reagent water blanks run on
that day (5% of samples run, minimum);
(4) the spike and surrogate percent recoveries for
the data set;
(5) the actual chromatograms, if requested by the
Department.
C. Identify, to the extent possible, thesource(s),
extent, and concentrations of contaminants, and the existence of
any imminent hazards.
7. The Department shall reVlew the PCAR and determine
whether it is adequate to meet the objectives of the PCAP.
In the
event that additional information is necessary to evaluate the
PCAR, the Department shall make a written request and Respondent
shall provide all requested information within 20 days of receipt
of said request.
B. Respondent shall provide notification to the Department
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at least ten days prior to the install~tion or sampling of any
monitoring wells, and shall allow Department personnel the
opportunity to observe installation and sampling and to take split
samples. All necessary approvals must be obtained from the
appropriate water management district before any wells 2re
installed. Raw data shall be exchanged beb-Jeen Respondcnt ond tIle
Department as soon as the data is available.
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9. The Respondent is required to comply with all local,
state and federal regulations and to obtain any necessary
approvals from local, state and federal authorities in carrYlng
out these assessment actions.
10. If the Department's review of the PCAR indicates that the
soil, sediments, surface water or ground water is contaminated, or
if the Department rejects the PCAP or PCAR for not meeting the
objectives or analyzing or reporting on the analysis of the
contaminants that are the subject of the assessment, the
Department .reserves the right t9 do any or all of the following:
A. seek further administrative relief through the filing
of a Notice of Violation or entry. of a Consent Order which
requires Respondent to .conduct further assessment and clean-up at"
its facility;
B. file suit for irijunctive relief, civil penalties,
damages and expenses, or
c. perform the necessary corrective actions at
Respondent's facility and recovery the costs of such actions from
Respondent.
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ExHIB II C
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CORRECTIVE ACTIONS FOR GROUND WATER CONTAMINATION CASES
1. Within 60 days of the effective date of the Order
incorporating these contamination assessment actions, Respondent
shall submit to the Department a detailed' Hritten Contamination
Assessment Plan ("CAP"). If the Respondent has conducted a
Preliminary Contamination Assessment, the Respondent shall submit
\
to the Department a detailed written CAP within 60 days of receipt
of notice from the Department that a CAP is required. The purpose
of the CAP shall be to propose methods for collection of
information necessary to meet the objectives of the coritamination
assessment.
A. The objectives of the Contamination Assessment shall
be to:
(1) Establish the areal and vertical extent of
soil, sediment, surface water and ground water contamination;
(2) Determine or confirm the contaminant source(s);
mechanisms of contaminant transport; rate and direction of
contaminant movement in the air, soils, surface water and ground
water; and rate and direction of ground water flow;
(3) Provide a complete characterization of the
contamination plume(s);
(4) Determine.whether interim remedial measures are
necessary to abate any imminent hazard.
(5) Det:ermine the amount of product lost, and the
time period over which it was lost (if applicable);
(6) If le~king storage tanks m2Y be the source of
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the contamination, determine the structural integrity of all
aboveground and underground storage systems (including integral
piping) which exist at the site (if applicable);
(7) Establish the vertical and horizontal extent of
free product (if applicable);
(8) Describe pertinent geologic and hydrogeologic
characteristics of affected and potentially affected hydrogeologic
zones; and
(9) Describe .geologic and hydrogeologie
characteristics of. the site which influence migration and
transport of contaminants; and
(10) . Provide a si te history including description
of facility operations, as applicable.
B. The CAP shall specify tasks, which are necessary to
achieve the objectives described in subparagraph 1.A. above. The
c~p shall include a reasonable time schedule for completing each
task. The t~sks may include, but are not limited to the following:
(1) Use of piezometers or wells to determine the
horizontal and vertical directions of .theground water flow;
(2) Use of electromagnetic conductivity (El!) and
other geophysical methods or vapor analyzers to trace extent of
ground water contamination;
(3) Use of fracture trace analysis, to discover
linear zones in which discrete flow could take place;
(4) Use of well points or monitoring wells to
sample ground water in affected areas and to determine the
vertical and horizontal extent of the ground water plume;
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the document titled -DER Guidelines for Preparing Quality
Assurance Plans, DER-QA-001/85, January 30, 1986.- A copy of the
document is available upon reque?t from the Department. A QAPP is
required for all persons collecting or analyzing samples. The
Department reserves the right to reject all results generated by
Respondent prior to QAPP approval or which are net in accordance
with the Department approved QAFP.
2. The Department shall review the.CAP and provide the
Respondent with a written response to the proposal. Any action
taken by Respondent with regard to the implementation of the CAP
.
prior to the Respondent receiving written notification from the
Department that the CAP has been approved shall be at Respondent's
risk..
3. In the event that additional information ~s necessary
for the Department to evaluate the ~~, the Department shall make
a written request to the Respondent for the information, and.
within 20 days from receipt of said request, Respondent shall
I
provide all requested information in writing to the Department
unless the requested information requires additional field work in
which case the Respondent shall submit to the Department within 14
days of receipt of said request, a written schedule for completing
the field work needed to provide the requested information.
4. In the E ~nt that the Department determines that the CP~
submitted by Resp .ndent does not adequately address the objectives
of the Contamination Assessment as set forth in subparagraph I.A.
above, the Department will notify the Respondent in writing of the
c.2l,;P's deficiencies. Respond..;, t shall then have 30 days from the
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Department's notification to submit a modified CAP addressing the
deficiencies noted by the Department.
5. If the Department determineS upon review of the
resubmitted CAP that the ~~ still does not adequatelY address the
objectives of the CAP as set forth in subparagraph 1.A. above, the
Department, at its option, may choose either to:
A. Draft specific modifications to the CAP and notify
Respondent .in writing that the Department's modification shall.be
incorporated in the CAP; or
B. Notify Respondent in writing that Respondent bas
failed to comply with paragraph four above, in which case the
,.
Department may do any or all of the following: take legal action
to enforce compliance with the, order, file suit to recover damages
.
and ci vi 1 penal ties, 0 r comp 1 et e the co rrecti've actions out 1 i ned
berein and recover the costs of completion from Respondent.
6. Once a CAP and QAPP have been approved by the Department,
they shall become effective and made a part of this Order and
shall be implemented within ten days of the Department's written
. notification to Respondent that the CAP and QAPP have been
approved. The CAP sball incorporate all.required modifications to
the proposed CAP identified by the Department. within 10 working
days of completion of the CAP tasks, Respondent shall provide
written notice to the Department that the CAP tasks have been
completed.
7 . Wi thin 45 days 0 f comp leti on of the tasks in the CAP,
Respondent shall submit a written contamination 1.ssessment Report
(nCARn) to the Department. The CAR .shall:
A. summarize all' tasks which were implemented pursuant
TD/Revised/GW/CA/0888.6
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to the CAP; . and
D. Specify results and conclusions regarding the
Contamination Assessment objectives outlined in subparagraph 1.A.
- 8. The Department shall review the CAR and determine whether
it has adequately met the objectives specified in subparagraph
1.A. In the event that additional information is ne~essary to
evaluate the CAR, the Department shall make a written request to
the Respondent for the information. Within 20 days of receipt of
sa~d request, Respondent shall provide all requested information
unless the requested information requires additional field work in
~1hich case the Respondent shall submit, within 14 days of said
request, to the Department a reasonable written schedule for
completing the.field work ~eeded to provide the requested
information. The Department shall provide written approval of the
9. The Department, at its option, may determine from review
of the CAR and other relevant information, the Site Rehabilitation
Levels (SRLs) to which the contamination shall be remediated or
. .
may require the Respondent to implement. the risk assessment
process to develop such SRLs for the site. The SRLs for water as
determined bi the D~partment shall be based ori Chapter 17-3,
F.A.C. standards and the Depar~ment's numerical interpretation of
the Chapter 17-3,F.A.C. minimum criteria. The Department may
also require that a risk assessment be completed to define SRLs
for soils or sediments that are sufficiently. contaminated to
present a risk to the public health, the environment. or the public
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welfare. If the Department does choose to provide SRLs to the
Respondent and does not choose to require a risk assessment and
the Respondent agrees to remediate the site to those SRLs, the
Respondent shall implement the Feasibility study, if required by
the Department as set forth in paragraph 13, or submit the
Remedial Action Plan (RAP) as set forth in paragraph 18..
10. After completion and Department approval of the CAR, the
Respondent shall prepare ~nd submit to the Department a Risk
Assessment/Justification (RAJ) if the Department requires the
task, or if the Respondent wishes to develop SRLs other than those
.
determined by the Department or if the Respondent intends to
justify a no-action proposal for the site. The RAJ which .includes
a risk assessment and a detailed justification of any alternative
SRLs or no action proposal. shall be ~ubmitted within (90) days
,
from receipt of the Department's written approval of the CA.-'ll and
determination of the SRLs for the site, or within (90) days of the
Department's written approval of the CAR and notice that a RAJ ~s
required, or within (90) days of the Department's written approval
of the CAR. Unless otherwise approved by the Department, the
subject document shall address the following task elements,
divided into the following five major headings:
A. Exposure Assessment - The purpose of the E~posure
Assessment is.to identify routes by which receptors maybe eJ::posed
to contaminants and to determine contaminant .levels to which
receptors may be.exposed. The i:posure Assessment should:
(1) Identify the contaminants found at.the site and
their concentrations as well as their e:l:tent and locations;
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(2) Identify possible transport pathways;
(3) Identify potential exposure routes.
(4) Identify potential receptors for each exposure
route; and
(5) Estimate or calculate expected contaminant
levels to which actual or potential receptors may be exposed.
B. Toxicity Assessment - The purpose of the Toxicity
Assessment is to define the applicable human health and
environmental criteria for contaminants found at the site. The'
criteria should be defined for ~ll potential exposure routes
identified in the Exposure Assessment. DER standards shall be the
criteria for constituents and exposure routes to which the
standards apply. Criteria for constituents and exposure routes
for which specific DER standards are not established shall be
based Upon criteria such as Recommended Maximum Contaminant Levels
(RMCLs), Maximum Contaminant Levels, Average Daily Intake values
(ADIs), Unit Cancer Risk values (VCRs), organoleptic threshold
levels, Ambient Water Quality Criteria for Protection of Human
Health and for Pr9tection of Aquatic Life, and other relevant
criteria as applicable. If there are no appropriate criteria
available for the contaminants and exposure routes of concern, or
the criteria are in an inappropriate. format, the Respondent shall
develop the criteria using equations and current scientific
literature acceptable to toxicological experts. Criteria for the
. following exposure routes shall be defined or developed as
applicable:
(1) Potable water exposure route - develop criteria
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utilizing applicable health criteria such as Recommended Maximum
contaminant Levesl (RMCLS). Maximum contaminant levels, Average
Daily Intake values (ADIs). Unit Cancer Risk values (UCRs),
-
organoleptic threshold levels. and other relevant criteria as
_ develop criteria for dermal contact. inhalation of vapors arid
(2) Non-potahle domestic water usage exposure route
applicable.
mists. ingestion of food crops irrigated with such water, lawn
watering. ingestion by pets and livestock. and other related
ingestion, dermal contact. i~alation. ingestion ~ h~ans or
(3) Soil exposure route - develop criteria for
exposure.
animals of~ood ;crop~.grown in contaminated soilS.
criteria for prevention of adverse effectS on human health (e.g.
(4) Non-potable surface water exposure - develop
dermal contact effects on humans utilizing the resource for
recreational purposes) or the environment (e.g. toxic effects of
the contaminants on aquatic or marine biota, bio_accumulative
effects in the food chain,other adverse effects that may affect
the designated use of the resource as well as the associated
biota).
(5)' Air e~osure rodte - develop criteria for
exposure to the contaminants in their unaffected state.
Characterization is to utilize the results of the ExpOsure
c. Risk Characterization - The purpose of the Risl~
Assessment and the Toxicity Assessment to characterize cumulative
(
Revised/GY~/C1V0888 ~ 10
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risks to the affected population and the environment from
contaminants found at the site. Based on contaminant levels
presently found at the site, a risk and impact evaluation will be
performed which considers, but is not limited to:
(1) Risks to human health and safety from the
contamination including;
(a) carcinogenic risk, and
(b) non-carcinogenic risk.
(2) Effects on the public welfare of exposure to
the contamination which may include but not be limited to adverse
affects on actually and potentially used water resources.
(3) Environmental risks in areas which are or will
be ultimately affected by the contaciination including;
(a) other aquifers,
(b) surface waters
(c) wetlands,
(d) sensitive wildlife habitats, and
(e) sensitive -areas including, but not limited
to, National Parks, National.Wildlife Refuges, National Forests,
State Parks, State Recreation Areas, State Preserves.
D. Justification.for alternative Site Rehabilitation
Levels (SRLs) or no action. proposal - The purpose of this section
I
is to provide justification on a case-by-case basis for a no
action proposal or for alternative SRLs that.vary from Chapter
17-3, F~A.C. standards and minimum criteria or from any SRLs
determined by the Department at which remedial action shall be
deemed completed. .Factors to ue evaluated shall be, at a minimum:
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(1) The present and future uses of the affected
aquifer and adjacent surface waters with particular consideration
of the probability that the contamination is substantially
affecting or will migrate to and substantially affect a public or
private source of potable water;
(2) potential for futher degradation of the
affected aquifer or degradation of other connected aquifers,
(3) The technical feasibility of achieving the SRLs
based on a review of reasonably available technology;
(4) Individual site char~cteristics, including
natural rehabilitative processes; and
(5) The results of the risk assessment.
.Applicable contaminant transport models must be employed to
document that human health and environ~ment risks from alternative
and less stringent SRLs are acceptable.
11. The Department shall review the Risk
Assessment/Justification document and determine whether it has
adequately addressed the risk.assessment task elements. The
Department shall review th~justification section and determine
whether the Department approves or disapproves of the alternative
SRLs or the no action proposal~
12. In the event that additional information is necessary to
evaluate any port~onof the Risk Assessment/Justification
docum~rit, the Department shall make a v~ritten request and
Respondent shall provide all requested information within 20 days
of receipt of said request. If the Department does not approve
the no action proposal or the alternative SRLs, the Responoent
.~
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shall use the SRLs as determined by the Department. If the
Department and Respondent agree to the remediation levels, either
the SRLs determined by the Department or the. alternative SRLS, the
Respondent shall implement the Feasibility Study,. if required by
the ~epart~ent as set forth in paragraph 13, or submit the
Remedi.al Action Plan (RAP) as set forth in paragraph 18.
13. The Department shall also determine from review of the
CAR and other relevant information whether the Respondent should.
prepare and submit a Feasibility Study (FS) to the Department.
The FS ~lill be required in complex cases to evaluate technologies
and remedial alternatives, particularly if multiple contaminant
classes are represented or multiple media are contaminated. The
purpose of the FS is to evaluate remedial technologies and
remedial alternatives.in or,der to identify the most
environmentally sound and effective remedial action to achieve
clean up of the site to SRLs or alternative SRLs (if approved).
The FS shall be completed within 60 days of written notice that a
FS is required, unless the Respondent plans to submit a P~J
pursuant to paragraph 10. The FS shall include the following
tasks:
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(2) implementabilitYi
(3) capital costs;
(4) operation and maintenance costs;
(5) operation and maintenance requirements;
(6) reliability;
(7) feasibility;
(8) time required to achieve clean-up; and
(9) potential legal barriers to implementation
of any of the alternatives;
(D) Iden~ify the need for pnd conduct pilot tests
or bench tests to evaluate alternatives, .if ~ecessary;
(E) Select the most appropriate ~emedial
alternative;
.
(F) Develop soil cleanup criteria such that the
contaminated soils will not produce a leachate which contains
contaminants in excess of the SRLs or alternative SRLs (if
approved).
14. Within 45 days of completing the'FS, Respondent shall
submi t an FS Report to the. Department. ' The FS Report shall:
A. Summarize all FS task results;. and
B. Propose a conceptual remedial action plan based' on
the selection process carried out in the FS. .
15. The Department shall review.the FS.Report for
adequacy and shall determine whether the Department agrees with
the proposed remedial action. In the event that additional
information is necessary to evaluate the FS report, the Department
~hall make a written request and Respondent shall provide all
Revised/GW/L~0888.14
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requested information within 20 days from receipt of said request.
16. If the Department does not approve of the proposed
reme9ial action, the Department will notify. the Respondent in
writing of the determination. The Respondent shall then have 20
days from the Department's notification to resubmit a proposed
alternate remedial action.
17. If the Department determines upon review of. the
resubmitted remedial action proposal that it does not agree with
the proposal, the Department at its option, may choose to either:
A. Choose a remedial action alternative for the
Respondent to carry out; or
B. . Notify the Respon~ent that Respondent has failed to
comply with paragraph 16 above, in which case the Department may
do any or all of the following: take legal action to enforce
compliance with the Order, file suit to recover damages and civil
penalties, or complete the corrective actions outlined herein and
recover the costs of completion from Respondent.
.18. Within ~5 days of receipt of written notice from the
D~partment, Respondent shall. submit to the Department a detailed
Reme.dial Action Plan. ("RAP") '. The RAP' shall be signed and sealed
by a .registered.professsional engineer in accordance with Chapter
471, Florida Statutes. The objective of the remedial action shall
be to achieve the clean up of the contaminated areas to the SP~s
or the approved alternative SRLs. The RAP shall include:
A. Rationale for the remedial action proposed which
shall include at a minimum:
(1) Results from any pilot studies or bench tests;
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D. .. A separate QAPP document;
E. Details of the treatment or disposition of any
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contaminated soils or sediments;
F. Proposed methodology including post remedial action
ground water monitoring as applicable for evaluation of the site
status after the remedial action is complete to verify
accomplishment of the objective of the RAP; and
G. Schedule for the completion of the remedial action.
19. The Department shall review the proposed RAP and provide
Reppondent with a written response to the proposal.
Respondent shall not implement the RAP until Respondent receives
written notification from the Department that the RAP has been
approved.
20. In the event that additional information is necessary for
the Department to evaluate the RAP, the Department shall make a
vlritten request to Respondent for the information, and Respondent
shall provide all requested information in writing to the
Department within 20 days from receipt of said request unless the
req~ested information requi~es additional field work in which case
the Respondent shall submit in writing to the Department a
reasonable schedule for completing the field work needed to
provide the requested information.
21. In the event that the Department determines-that the RAP
submitted. by the Respondent does not adequately address the
objectives set forth in paragraph 18, the Department ~lill notify
the Respondent in writing of the RAP's deficiencies. The
Respondent shall then have 20 days from the Department's
notification to submit a modified RAP addressing the deficiencies
noted by the Department.
resubmitted RAP that the RAP still does not adequatelY addresS the
22.
If the
I
Department determines upon revie~ ol the
,,- ,-~
ohjectives of the RAP, the Department, at its option, may choose
to eithe:r:
notifY the Respondent in ~riting that the Department's
modifications shall be incorporated in the RAP; or
B. Notify the Respondent that Respondent haS failed
h. Draft specific modifications to the RAP and
to comply ~ith the paragraph 21 above, in ~hich case the
Department may do any or all of the follo~ing: take legal action
to enforce compliance with the order,file suit to recover damages
and civil penalties. or,comPlet~the.corrective .ctions outlined
herein and recover the costs of completion from Respondent.
23..0nce aRAPchas been-approved bY the Department,it shall
becO~ effective arid made a part of this order and
shall be implemented ~ithin ten dayS from receipt of the
Department's notification to the Respondent that the RAP haS been
approved. The R1IP shall incorporate all required modifications to
the proposed RAP. identified by. the Department. .
24. Follo~ing termination_o~ re~dialaction (clean up.of the ~
oontaminated. area to. the SRLs 6rthe approved alternative SIlLs),
designated monitoring ~ells shall be sainpied.on a ,schedule
dete:rmined by .the Department.
25. Follo~ing completion of .theremedial action and
post_r~edial action monitoring, the_~spondentshall s~mit a
site Rehabilitation completion Report (SRCR) to the Department for
approval. The SRCR shall be signed and sealed by a registered
Revised/GW/CA/0888.18
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Professional Engineer in accordance with Chapter 471, F.S., unless
"no further action" or "monitoring-only" was proposed and was
approved by the Department. The SRCR shall contain a
demonstration, with supporting documentation, that'site cleanup
objectives have been achieved.
26. Within sixty (60) days of receipt of the SRCR, the
Department shall approve the SRCR or make a determination that the
SRCR does not contain sufficient information to support the
demonstration that cleanup objectives have been achieved.
27. If the Department determines that the SRCR is not
adequate based upon information provided, the Department will
, notify the
Respondent in writing. Site .rehabilitation activities shall not
be deemed completed until such time as the Department provides the
Respondent with written notice that the SRCR is approved.
28. On the first working day of each month, after beginning
implementation of a CAP or RAP, Respondent shall submit written
progress reports to the Department~ ~hese progress- reports shall
describe the status of each required CAP and RAP task. The
reports shall be submitted .until planned tasks have been completed
to the ,satisfaction of the Departm~nt:
29. Respondent shall provide wri tten .no'tification. to the
.' - . .
Department at least ten d~ys pri~rto iristalling m6nit6riri~ or
recovery wells~ and shall allow Department personnel the
opportunity to observe the location and installation of the wells.
All necessary approvals must be obtained from the water management
district before Respondent installs the wells.
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30. Respondent shall provide written notification to the
Department at least ten days prior to any sampling, and shall
allow Department personnel the opportunity to observe sampling or
to take, split samples.' Raw data shall be exchanged between the
Respondent and the Department as soon as the data is available.
31. The Respondent is required to comply with all applicable
local, state and federal regulations and to obtain any necessary
approvals~romlocal, state and federal authorities in carrying
out these corrective actions.
32. If.any event. occurs which:~auses delay or the reasonable
likelihood o~ delay,in the, achievement of the requirements of
thes~ c6rrectiveActions,~Respondent shall have. the burden of
proving that the delay was or will be caused by circumstances
, .
. beyonc:l. . the.. reasonable contro ~ of. Respondent, and. could not have
b~en or can not be overcome by due diligence. Upon occurrence of
the event Respondent shall promptly .notify the Department orally
and shall, .within seven.cal~nd~r.days~ no~ify, the Department in
writing of the anticipated le?gt~.~nd .cause of delay, the measures
take?or~obe.ta~entopreyento,. nlipimjze the delay , and the
. .
timetabl~ by wl:d<:h R.~sP().l1d,e~t:in.tendsto :,impleI!lent, these "
measures. .If. thepa~ties. can agree that the delay
.. ~ ~ ., .' _... 4'" -. . . - ". ~- . . -,' ......
or ant\icipated delay has been,?!:,: ~ill ,bE? caused. by.cir:cumsi:anc~s ,
.' - -.
beyond .:t7hereasonable',contiol.Of.~esp6nde~i) ~heiti~~ f?r;
. .. ..' - ,.-. ... .... -. ...,.. -......... ".' .,.:.-.-. ..-",.~ ',.-.:."'.'. ;.... .:..' ....::... ...,.....
performance h!"reuI1der shallbe ~>:tended fo.r. a period equal to the
delay resulting from such circumstances. , Such agr~ement shall be
confirm~dby letter.from.the Department accepting or if necessary
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modifying the extension request. Respondent shall adopt all
reasonable measures necessary to avoid or minimize delay. Failure
of Respondent to comply with the notice requirements of this
paragraph shall constitute a waiver of Respondent's right to
request an extension of time to complete the requirements of these
Corrective Actions. Increased costs of performance o~ any of the
activities set forth in these Corrective Actions or changed
economic circumstances shall not be considered circumstances
beyond the control of Respondent..
33. Respondent shall immediately notify the Department of any
problems encountered by Respondent which require modification of
any task in the approved CAP or RAP, and obtain Department
approval prior to implementing any such modified tasks.
34. Should the Department conclude that clean up of the
contaminated area to SRLs or approved alternative SRLs, is not
feasible; or should Respondent.not completely implement the RAP as
approved by the Department; the Department may seek restitution
from Respondent for enyironmental.damages resulting from pollution
as a result of Respondent's actions. W~thin20 days of receipt of
Department written notification of its intent to seek said
restitutiori,Respondent may pay.th~amount of th~ damages or may,
if. it so ~hooses,initiatenegotiations with the D~part~ent
. ..
regarding the monetary terms of reititution to the state~
Respondent is aware that should a negotiated sum or other
compensation for environmental d~mages not be agreed.to by the
Department and Respondent within 20 days of receipt of Department
.
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written notification of its intent to seek restitutionr the
_~ Department may institute appropriate action, either
administrative, through a Notice of Violation, or judicial, in a
.,.
court of competent jurisdiction through a civil C6mplaint, to
recover Department assessed environmental damages pursuant to
Section 403.141, Florida statutes.
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