The scenario is played out over and over again every day when the question is posed “has this fueling station underground storage tank system had a reportable release”. The question may be posed as a result of a pending real estate transaction, a lender or financial institution’s decision regarding a loan or investment, or even from a concerned adjacent property owner.
Older fueling stations may already have had one or several leaking petroleum storage tank (LPST) incidents assigned to them that were closed under the Texas Petroleum Storage Tank pre / post risk-based assessment standards or even under the Texas Risk Reduction Program. These UST fueling systems have had a legacy release resulting in soil and groundwater contamination below regulatory clean-up standards. Therefore, a re-evaluation of the UST system though the use of invasive soil and groundwater sample and chemical analysis may “rediscover” the original contamination leaving the false impression that there is a new release. A simple review of the site’s LSPT files in Austin could correct this false assumption.
Another scenario that could lead to a false conclusion that a new release has occurred, is the belief that if soil or groundwater contaminant concentrations are higher in the current assessment than those reported in a former LPST report, a new release must have occurred from the UST. This potential error made by many consultants could result in a new LPST designation, the installation of one or many monitoring wells, and possible unnecessary groundwater monitoring, remediation, and closure costs typically borne by the unsuspecting owner, financial institution, or insurance company.
Before such a conclusion is drawn by a consultant, a stakeholder needs to be advised there are other lines of evidence that can be assessed to prove or disprove that a new release has occurred:
Is there evidence for a loss of fuel such as inventory discrepancies, failed piping or tank tightness tests, leak detection alarms, or hydrocarbons in the tankhold observation wells.
Are there detectable presence of compounds such as MTBE, other oxygenates, TAM, DIPE, lead, priority additives, that could assist in dating the release. Fingerprinting techniques can also be used to date the source of the release. Review of repair and tank testing documentation can better define the source of the release – whether it is tankhold overfill, faulty spill bucket, or a tank/dispenser piping release.
Before reporting evidence of a new release based on an increase of contaminant concentrations in the groundwater at a UST release legacy site, gather other forms of evidence to reinforce the case for or against the assignment of a new LPST number. The TCEQ actually encourages additional assessment as they rely on the accuracy of your consultant’s determination to make their decision. It will save everyone a lot of grief.