Project Overview
ESE completed a tank removal and release determination for a diesel underground storage tank at an active healthcare facility in Texas, delivering regulator-ready documentation to support compliant closure and reduce environmental liability. The work included oversight of removal activities, confirmatory soil sampling, laboratory analysis, and preparation of a Release Determination Report for submittal to the Texas Commission on Environmental Quality.
Challenges
Healthcare campuses often require tank removals to be completed efficiently and safely while maintaining ongoing operations, site access, and schedule certainty. In addition to field execution, closure success depends on defensible sampling and complete documentation that meets TCEQ expectations for removal-from-service submittals, including clear records of tank condition, waste handling, and analytical results.
ESE’s Approach
ESE coordinated removal activities with qualified contractors and verified safe removal conditions by screening for explosive vapors prior to excavation and tank handling. Following removal, ESE documented tank condition through inspection and photographs, then collected confirmatory soil samples from the tank-hold area and associated soil stockpile consistent with TCEQ guidance for release determinations. Samples were managed under proper chain-of-custody procedures and submitted for laboratory analysis of diesel-related constituents, and field observations confirmed that groundwater was not encountered during removal activities.
Key Elements Delivered
- Vapor screening performed to confirm safe conditions for removal activities
- Tank inspection and photographic documentation to support closure records
- Confirmatory soil sampling consistent with TCEQ release determination guidance and protocols
- Disposal documentation and supporting attachments including mapping, photo logs, analytical summaries, and laboratory reports
- Updated regulatory documentation prepared for submittal following removal from service
Results
Laboratory results from confirmatory sampling indicated no actionable petroleum release associated with the former tank area, and the Release Determination Report was prepared for submission to TCEQ as removal-from-service documentation. Based on removal documentation and sampling results, ESE requested that TCEQ issue a No Further Action letter to support regulatory closure.
Project Impact
Tank closures at operating facilities require a balance of safe field execution, careful documentation, and defensible sampling to avoid delays and future liability. By delivering a complete tank removal and release determination package aligned with TCEQ expectations, ESE helped the healthcare facility close out regulated tank obligations with confidence and a clear path to regulatory closure.
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