developing Bio Remediation collodial chemistry for Water and Soils that are
toxic.
This is from the ole dummy don.. lol Oh yes I own 1st Enviro Safety and
you can visit us at www.1stenvirosafety.com
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Dear Mr. Wilshe:
The Bureau of Petroleum Storage Systems hereby acknowledges receipt of a
confidential disclosure dated July 2, 2003, submitted by
1st EnviroSafety Incorporated, regarding the proprietary ingredients and
their
proportions in the remediation product known as ECCO Commercial All Purpose
Cleaner, for petroleum cleanup in groundwater and soil pursuant to Chapter
62-770, F.A.C. ECCO Commercial All Purpose Cleaner does not contain
microorganisms but is rather an organic aqueous solution that emulsifies
petroleum hydrocarbon contaminants.
The bureau hereby also acknowledges receipt of supplemental correspondence
dated September 18, 2003 from 1st EnviroSafety Incorporated, indicating that
the surfactant ingredient will be omitted from ECCO Commercial All Purpose
Cleaner that is marketed in Florida for groundwater remediation purposes.
Florida regulations do not prohibit the use of a surfactant for the
remediation of a petroleum-contaminated aquifer, but minimum groundwater
criteria for the surfactant must first be established for listing in Chapter
62-777, F.A.C., if the surfactant is of toxicological or environmental
concern. It was the choice of 1st EnviroSafety Incorporated at this time to
simply omit the surfactant as an ingredient, rather than have minimum
groundwater criteria developed for it, since tests showed that ECCO
Commercial
All Purpose Cleaner is also effective without the surfactant. If at some
time
in the future there is a desire to once again include the surfactant as an
ingredient, then minimum groundwater criteria will have to be established
before it is introduced to an aquifer.
Having reviewed the confidential disclosure, the bureau hereby vouches for
the
composition of the product. Without divulging any proprietary aspects of the
product, we provide the minimum amount of necessary information -- in as
general terms as possible -- to potential users of ECCO Commercial All
Purpose
Cleaner and reviewers of plans proposing it in order for them to comply with
the regulations that apply. This is done below for four (4) categories, each
of which is labeled in bold-faced type. By reading the information that the
bureau has provided for each category, users and reviewers will know whether
there is an obligation to comply with a regulation. Additionally, for each
category, the bureau has either indicated why a particular ingredient or
parameter is a concern (or is not a concern) with respect to underground
injection control regulations. If in any category there is a judgment made
by
the bureau, then an explanation or a rationale is given.
pH. When one (1) volume of liquid ECCO Commercial All Purpose Cleaner
concentrate is mixed with fif*** (15) volumes of water prior to injection,
the resulting pH of the fluid to be injected is approximately 9.72, which is
not within the 6.5 to 8.5-range required by the secondary drinking water
standards of Chapter 62-550, F.A.C. Therefore, rule 62-522.300(2)(c),
F.A.C.,
applies. In order to comply with this rule a Department-approved Remedial
Action Plan must: (a) identify the pH of the fluid to be injected as a
parameter that does not meet its secondary drinking water standard;
(b) specify the size and duration of a zone of discharge associated with pH;
and (c) propose groundwater monitoring of pH.
62-777, F.A.C.-listed chemical species. There are two proprietary chemical
species present in ECCO Commercial All Purpose Cleaner that are listed in
the
current August 5, 1999 issue of Chapter 62-777, F.A.C., for contaminant
cleanup target levels. The Bureau of Petroleum Storage Systems hereby
vouches
that the injected concentration of neither of these two species will exceed
its respective minimum groundwater set forth in that chapter when
one (1) volume of liquid ECCO Commercial All Purpose Cleaner concentrate is
mixed with fif*** (15) volumes of water prior to injection.
Ammonia Nitrogen and TRPH. Per laboratory analysis of the proprietary fluid
to be injected at a concentration of one (1) volume of liquid ECCO
Commercial
All Purpose Cleaner with fif*** (15) volumes of water, the concentrations
of
total recoverable petroleum hydrocarbons (TRPH) and ammonia nitrogen will
exceed their respective minimum groundwater criteria of 5,000 and
2,800 micrograms per liter (ug/L). 1st EnviroSafety Incorporated must
therefore petition for a zone of discharge variance to temporarily exceed
the
5,000 ug/L minimum groundwater criterion for TRPH and the 2,800 ug/L minimum
groundwater criterion for ammonia nitrogen set forth in Chapter 62-777,
F.A.C.
The petition is for a variance from Rule 62-522.300(3), F.A.C., and
instructions and a petition format can be obtained at web page
www.dep.state.fl.us/waste/categories/pcp/pages/innovative.htm. The zone of
discharge variance must be granted before ECCO Commercial All Purpose
Cleaner
can be injected for the purpose of in situ aquifer remediation.
FDA EAFUS-listed ingredients. Several proprietary ingredients or chemical
species present in ECCO Commercial All Purpose Cleaner are listed in the
U.S.
Food and Drug Administration (FDA) food additive inventory database that is
often referred to as "Everything Added to Food in the United States"
(EAFUS).
The Bureau of Petroleum Storage Systems, without divulging the proprietary
identity of these ingredients and chemical species, would like to indicate
that the magnitude of the concentration of each of these chemical species in
the fluid to be injected is not greater than five (5) parts per million
(ppm).
Given that these ingredients and chemical species are present in such low
concentrations, and listed in EAFUS as well, the Bureau of Petroleum Storage
Systems judges that they should be of minimal toxicological and
environmental
concern. However, should the EAFUS status of these ingredients and chemical
species change in the future, or should a valid toxicological or
environmental
issue be raised about any of them, then minimum groundwater criteria may
have
to be developed and imposed.
For underground injection control purposes, remediation plans proposing ECCO
Commercial All Purpose Cleaner must provide the volume and composition of
the
fluid to be injected into an aquifer. Since the composition is proprietary,
it will suffice to indicate the overall volume of ECCO Commercial All
Purpose
Cleaner solution to be injected (at the 15:1 dilution by volume strength)
and
provide a footnote indicating that a one-time confidential disclosure
regarding the proprietary composition has been submitted to the Department.
Reference should be made to the original July 2, 2003 disclosure and also
the
supplemental September 18, 2003 correspondence indicating that the
surfactant
is omitted from the formulation when it is injected in Florida, and a copy
of
this voucher should be included as an appendix in the plan.
Sincerely,
Rick Ruscito, P.E. Rebecca S. Lockenbach
Ecology and Environment, Inc. FDEP Section Leader
Bureau of Petroleum Storage Systems Bureau of Petroleum Storage Systems
Petroleum Cleanup Section 6 Petroleum Cleanup Section 6
Donald R. Wilshe, CEO
1st Enviro Safety, Inc.
10200 Betsy Parkway
St. James City, Florida 33956
http://www.racesimcentral.net/
888 578 9600
FAx: 888 485-8765
USA: 239 283-1222
--
Donald R. Wilshe, CEO
1st Enviro Safety, Inc.
10200 Betsy Parkway
St. James City, Florida 33956
http://www.racesimcentral.net/
888 578 9600
FAx: 888 485-8765
USA: 239 283-1222