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Due diligence for the demolition and redevelopment of the client’s light industrial manufacturing complex led to WGI’s identification of imminent regulatory enforcement of an unaddressed petroleum system release at the heavy equipment Maintenance Facility. Upon notifying the client, WGI was authorized to conduct the required assessment of the impact on the facility’s soil and groundwater under the State’s Contamination Cleanup Criteria rule.
As a part of the assessment, WGI’s review of the facility’s storage tank system compliance records identified failures and enforcement notifications. The client authorized WGI to address the petroleum storage tank system compliance issues. WGI’s records review and contractor communications found that the petroleum storage system repairs and maintenance posed an exorbitant and continuing cost burden to W. W. Gay. Remnant soil impact identified by the release-related assessment posed a risk to unconditional closure of the contamination incident forcing the implementation of an engineering control and deed restriction.
Given the pending cost of addressing the petroleum storage systems’ compliance issues and the possibility of imposed controls/restrictions, WGI provided the option to eliminate both by closing the UST systems through removal, which simultaneously eradicated the remnant petroleum-impacted soil identified by the site assessment. This action resulted in regulatory approval of the unconditional closure of the reported petroleum release.
• A unique solution simultaneously eliminated existing soil contamination issues, the exorbitant and continuing cost burdens of maintaining the facility’s UST systems, and future liabilities for potential petroleum release. Removal of the impacted soil simultaneous with the petroleum storage tank extractions allowed unrestricted closure of the reported incident of related soil contamination, diminishing the possibility of complications of potential future redevelopment of the facility.
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