Underground Storage Tank Investigation and Remediation
In response to potential problems associated with product leaking from underground storage tanks (USTs), the U. S. Congress enacted a program in Subtitle I of the Hazardous and Solid Waste Amendments (HSWA) in 1984. The purpose of Subtitle I was to control and prevent leakage from USTs. In response to HSWA, the USEPA promulgated regulations that cover the following areas: (i) UST system design, construction, installation, and notification; (ii) general operating requirements; (iii) release detection; (iv) release reporting, investigation, and confirmation; (v) release response and corrective action; (vi) closure of out-of-service units; and (vii) financial responsibility. ECA has extensive experience in these areas.
UST REMOVAL AND CLOSURE REPORTING AND DOCUMENTATION
The Federal UST regulations require that out-of-service USTs be properly closed within 1 year. Closure includes sampling of soil and groundwater, if encountered beneath USTS, lines, and dispensers, and reporting of any detected releases within 24 hours. ECA has performed many UST closures and has provided the documentation required by the regulations. The services provided by ECA can include agency notification and coordination, turnkey UST system removal, soil and groundwater sampling, photo documentation, laboratory testing, tank destruction, and required closure reporting.
CORRECTIVE ACTION PLANS
The Federal regulations require that a Corrective Action Plan (CAP) be developed for any site where a release has occurred that requires remediation. A CAP must contain a complete assessment of soil and/or groundwater impact. A CAP summarizes all existing soil, groundwater, and surface-water analytical data, as well as evaluates the movement of groundwater beneath the property using fate and transport models. Typically, a CAP will contain tabulated data and figures such as groundwater potentiometric maps, cross sections, and isocontour maps, boring logs, and well logs. In addition to a full delineation of the extent of releases to soil and groundwater, the CAP will contain an evaluation of the applicable state remedial standards for each media, as well as a design to achieve the applicable cleanup standard.
GROUNDWATER AND SOIL REMEDIATION
ECA has considerable experience meeting the requirements of the various state agencies and their regulations, particularly in the southeast. ECA has designed various remediation systems for cleanup of soil and groundwater, for inclusion in CAPs. Typical remedial technology appropriate for petroleum hydrocarbon releases include SVE, DPVE, in-situ or ex-situ bioremediation, limited soil excavation and disposal or treatment, passive soil venting, groundwater and free product recovery and treatment, and air sparging. ECA has been successful in negotiating alternative cleanup levels through the use of groundwater modeling and other modeling techniques. A passive approach to remediation (natural attenuation) is also considered an alternative where contamination is limited.
TRUST FUND CLAIMS AND REIMBURSEMENT APPLICATIONS
Most state agencies have developed trust funds as a mechanism for reimbursement of costs associated with releases of petroleum products from USTs. Participation in a trust fund is one method of providing financial responsibility as required by the Federal regulations. Participation in a fund typically involves payment of a fee to the fund on each gallon of petroleum product purchased. In the event of a release, a participating owner/operator is then eligible to request reimbursement of his assessment and remediation costs, after a deductible is reached. ECA has been extremely successful in obtaining reimbursement of costs for our clients, through trust fund claims. Usually, a reimbursement application and trust fund claim are prepared during the CAP stage described previously. The claim will typically include documentation of the owner's eligibility and compliance with the regulations, as well as a tabulation of all eligible expended and projected costs to remediate a release.
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