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Rockin’ and Rollin’ To Regulatory Closure

Whitehead E. S. is assisting a real estate developer to remediate and close a contaminated property through the Texas Commission on Environmental Quality’s (TCEQ’s) Voluntary Cleanup Program (VCP) and Leaking Petroleum Storage Tank (LPST) Program. The property is located in Old East Dallas and was historically developed with a gasoline service station from the mid-1930s until the early-1950s. A total of eight unregistered underground storage tanks (USTs) were identified on the property and removed from the ground by a licensed contractor in May 2017.


Sampling conducted by another consultant identified elevated concentrations of lead (above 1,800 parts per million or ppm) and trace concentrations of arsenic and gasoline range VOCs in the soil. The estimated cost to remediate and close the Site through the TCEQ was over $300,000. As a result, the property owner contacted Whitehead E. S. to develop a more cost effective strategy to address the impacted soil, and ultimately cleanup and close the Site.


Whitehead E. S. entered the Site into the TCEQ VCP, conducted on-Site soil and groundwater sampling, off-Site background soil sampling for metals, delineation sampling to reduce the footprint of impacted soil, Tier 2 calculations for arsenic and lead, and communicated extensively with the TCEQ case coordinator to work through project issues. The additional soil delineation along with the use of a higher cleanup level for lead (approved by the TCEQ) resulted in a much smaller volume of soil requiring excavation and off-Site disposal. Because the Site was historically a gasoline service station, the TCEQ requested that an Assessment Report Form (ARF) be submitted and the chemicals of concern (COCs) related to the former tanks addressed in accordance with Petroleum Storage Tank (PST) Division guidance.


Whitehead E. S. completed all Site work and is working with the TCEQ to wrap up the VCP case with issuance of the Certificate of Completion along with a Final No Further Action letter through the LPST Program. The total cost of this project including sampling, remediation, and closure through the TCEQ VCP/LPST was less than $75,000. At Whitehead E. S., we don’t skip a beat to get your project closed!

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