Environmental due diligence, Underground Storage Tank and Soil Remediation Activities for Redevelopment of Truck Stop
One of AKT Peerless’ major petroleum retail clients was interested in purchasing a former truck stop (Sun Petro) in order to own, brand, and operate their first truck stop in Georgia. The property that was purchased contained the following seven existing underground storage tanks (USTs): one (1) 4,000-gallon kerosene tank; two (2) 20,000-gallon diesel fuel tanks; three (3) 10,000-gallon gasoline tanks; and one (1) 6,000-gallon diesel fuel tank. Additionally, the former Sun Petro facility had one (1) kerosene pump dispenser; four (4) gasoline pump dispensers; and 18 diesel fuel pump dispensers that required removal. The facility also contained a truck service garage with an oil-changing pit and a truck washing station equipped with an oil-water separator.
Prior to acquiring this former truck stop, our major petroleum retail client retained us to perform the following services: (1) Phase I and II Environmental Site Assessments (ESAs) as part of their due diligence; (2) remove the seven underground storage tanks (UST) to accommodate their two new UST systems; (3) use ground penetrating radar (GPR) to identify any potential anomalies; and (4) excavate and dispose of any soil contamination encountered above the regulatory standards. As part of the Phase I ESA, we discovered that Sun Petro had a previous gasoline release that impacted soil and groundwater quality at the property. Following several years of remediation, the state agency granted Sun Petro with a no further action (NFA) letter. Our Phase II ESA identified a number of areas that still exhibited elevated, residual soil and groundwater contamination. Given that this contamination was present within the newly proposed building footprint and other sensitive areas, construction plans were amended to install a 60-mil vapor barrier to minimize any potential vapor intrusion concerns. AKT Peerless then performed a GPR survey and identified several buried anomalies that were identified to be a former tank pit on the southeast corner of the property and a buried steel tank that was used as an oil-water separator near the truck service garage. This oil-water separator was removed and these areas sampled and tested. Sampling and testing was also conducted beneath the removed oil-water separator associated with the truck washing station and beneath the oil-changing pit when the truck service garage was demolished. During the UST system removal activities, several areas identified extensive soil contamination, particularly in the truck stop portions beneath the 18 pump dispensers. Upon completion of all sampling and testing activities, AKT Peerless calculated approximately 3,000 tons of Total Petroleum Hydrocarbon (TPH) impacted soils near and above its allowable limits for when being permitted to remain on-site.
Despite the high TPH-impacted soils near and above its allowable limits to remain on-site, it was the opinion of the state agency that the contamination was not significant enough to pose a risk to human health. Therefore, AKT Peerless was able to transfer and update the prior NFA letter into their client’s name. In good faith, this client still elected to excavate and dispose of the impacted soil encountered during the UST closure activities, and beneath any building pads and underground stormwater detention areas.
