No Further Action Letter for Tank on Dallas Property

Whitehead E.S. recently assisted a south Dallas entity with assessment of a commercial property and subsequent removal of an “out of service” gasoline underground storage tank (UST).  Whitehead E. S. performed a Phase I ESA of the property that identified an out of service gasoline UST as a Recognized Environmental Concern (REC).  Whitehead E. S. subsequently conducted a Phase II Investigation consisting of soil and groundwater sampling to determine if the Petroleum Storage Tank (PST) system had adversely impacted the Site and ultimately the value of the property.  The Phase II Investigation indicated that soil and groundwater around the UST system were not impacted from petroleum compounds and/or gasoline related volatile organic compounds (VOCs).  Although not a source of contamination, the future property owner wanted the UST system removed from the property as part of their re-development plan.

Whitehead E. S. assisted the property owner with selecting a licensed tank removal firm, oversite of the UST removal process, sampling in accordance with TCEQ guidelines, and documentation to the TCEQ.  Even through soil and one groundwater sample were collected in the area of the UST and pump, additional sampling was required under the TCEQ guidance under Regulatory Guidance RG-411.  Based on review of the tank removal report and Release Determination Report submitted by Whitehead E. S., TCEQ issued the new property owner with a No Further Action Letter on September 3, 2019.


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