Whitehead E. S. recently assisted a client in closing a former bakery in Dallas through the Texas Commission on Environmental Quality’s (TCEQ’s) Petroleum Storage Tank (PST) Program. The property historically operated as a distribution facility for baked bread from at least 1950 until 1970. During that time, a 1,000-gallon gasoline underground storage tank (UST) was used to fuel delivery vehicles. A Phase I Environmental Site Assessment (ESA) was conducted on the property in October 2019 that identified the historical UST as a recognized environmental condition (REC), based on the 20 years of operation. PSTs were not regulated by the State of Texas until 1989 when the Texas legislature expanded and funded the PST Program. Due to the lack of regulations at the time of the facility closing, the tank was abandoned in place.
Whitehead E. S. was contracted by the property owner to determine if the Site was impacted from the historic PST and associated pump island. Soil and groundwater samples were collected around the tank pit and pump. Analytical results indicated the Site had not been negatively impacted; however, the UST still needed to be removed from the ground prior to any redevelopment of the property. Whitehead E. S. provided oversight for the tank removal and associated confirmation sampling from the tank pit and pump island in accordance with TCEQ guidance. Soil samples were collected and analyzed for petroleum-related compounds, which were below their respective PST Division Action Levels. The Tank Removal Report was submitted to TCEQ for review and TCEQ noted that one of the stockpile samples had an elevated concentration of total petroleum hydrocarbons (TPH) that needed further evaluation. Follow up sampling indicated that polycyclic aromatic hydrocarbon (PAH) concentrations were low and TCEQ subsequently issued a No Further Action Letter. Note that we had originally planned to dispose the stockpiled soil into a landfill but due to lower than anticipated laboratory results, placed the stockpiled soil back into the tank pit.
Now that the case is closed, the property owner can move forward with redevelopment. At Whitehead E. S., we like to say that cleanup and regulatory closure are the “yeast we can do”.
