Learn why Phase I Environmental Site Assessments almost always identify Recognized Environmental Conditions (RECs) at gas stations, service stations, and vehicle repair shops.
Many times when potential customers contact us for more information about Phase I Environmental Site Assessments, a gas station invariably pops up in the discussion. Whether there's a vehicle repair shop across the road, a service station next door or the site used to contain a former gas station, getting a Phase I is vital to ensure you know if there's any contamination at the site in question.
Folks know it's important, but tend to downplay the job before we ever begin by saying things like "the gas tanks were removed, so there shouldn't be anything to worry about, right?" or do I really need a Phase I ESA? or something along those lines. Like many other questions posed by those seeking a Phase I within proximity of a gas station, the answer is often no, that's not correct. In fact, there may be, and often are, numerous things we run into at these types of facilities that get identified as RECs in the Phase I routinely.
So let's dive into it and cover RECs at gas stations, service centers, and repair shops, and learn a little more about Phase I's in the process.
Those links will help educate you on the subject of a Phase I and give you a good baseline education for the rest of this article.
The short story on RECs is as follows: a REC is a recognized environmental condition, and the identification of RECs at a property is the sole purpose of a Phase I ESA under ASTM standards. So, the identification of RECs is the sole reason for doing a Phase I ESA, that's it. You might be surprised to learn this, but making recommendations on further action or no further action is not part of the ASTM standard. A Phase I is just for identifying Recognized Environmental Conditions, that's it.
Does a REC mean that there's a problem? Maybe, but maybe not. The consideration of whether it's worthy of further investigation is up to the environmental professional. While recommendations are not part of a Phase I ESA strictly speaking by the standards, they're usually requested by our clients.
So I, as an environmental professional, may identify some condition as a REC at your gas station during the Phase I process, whatever it may be. That's it, I've done my job. However, if you asked, I may then make recommendations as to whether or not I conclude that this REC is significant enough to warrant further investigation. I might, or I might not, depending on what I've identified. It all depends on what's identified.
Long story short, not all identified RECs automatically are a problem, a deal-breaker, something that's going to cost a fortune to deal with, or require further investigation via a Phase II investigation. Maybe it will, maybe it won't.
Also know this: a REC cannot be a thing. Despite what many cut-rate Phase I ESA practitioners out there claim, a REC is only the presence or likely presence of hazardous substances or petroleum products at the subject property. So an underground storage tank is not a REC, it's the likely presence of petroleum from the underground storage tank that's the REC.
Let me give you an example. Part of the definition of a REC is "the presence or likely presence of hazardous substances or petroleum products at, on or in a subject property due to conditions indicative of a release".
So let's say we go out to a former gas station site, which is now closed. They used to use a small aboveground heating oil tank behind the gas station, but it was removed many years ago. I know, from records and interviews, that there used to be a small tank there, but I don't see any sign of the tank, no pipes into or out of the building, no stained soils or distressed vegetation, no pad, no cradle for the tank, no nothing. In fact, I might not be all that sure exactly where the tank was!
So might I call this a REC? Yes, in all likelihood.
But would it necessitate further investigation? It might, or it might not, depending on the conclusions I would make during the investigation.
If things didn't look right and the site was a mess, I'd probably recommend some further investigation (soil and possibly groundwater sampling) at the likely tank location. But if the site was neat and clean, they had records of the removal of the tank in the past, maybe photos which didn't show any staining and the tank in good condition, maybe I wouldn't recommend further investigation.
This is kind of like the "art" part of a Phase I, rather than hard and fast "science".
Common RECs Identified in a Phase I ESA at Gas Stations, Service Stations, and Repair Shops
So is it only tanks that we'd have to look for when doing a Phase I ESA at a gas station, service station, or repair / maintenance shop? No, there's usually quite a few things to look at/for. Here's a sample of some of the most common ones we have seen, and what we're looking for the moment we step on the site:
Underground Storage Tanks (USTs)
Normally we look a variety of signs and ask ourselves, the site representative, and the buyer of the Phase I things such as:
Were they present?
Have they been removed?
Do we know where they were?
Were they removed with appropriate regulatory oversight?
Was there testing done on soil and groundwater after removal?
Were the tanks filled in place?
Did they test below the tank?
Who did the work, and when?
What regulations were in effect at that time, and how do those regulations compare to today?
Was enough testing done?
If USTs are still present, are they upgraded to present standards?
As you can see, a lot of questions to address when it comes to USTs. Simply put, the current or past presence of USTs is not only a no-brainer, it's going to mean the identification of a REC in a Phase I ESA at a gas station, service station, wherever almost no matter what.
If you see a Phase I completed at a gas station that doesn't identify a UST as a REC, do yourself a favor and see if you can get your money back.
Above-ground Storage Tanks (ASTs)
Same as for USTs. They're going to be RECs, even if they're brand new. Why? Ask yourself these questions:
Do tank users often spill a little?
What would those small spills over time mean?
Could they cause soil contamination or groundwater contamination?
These would be conditions indicative of a release since we all know that spills will cause some level of contamination. So these, no matter their condition or no matter their age, their presence is going to result in the identification of RECs.
Again, if a Phase I ESA doesn't identify these as a REC, I question whether that report is useful or not.
Structures Associated with USTs & ASTs
I'm referring to piping, pumps, sumps below pumps and tanks, etc. All of these will likely result in the identification of RECs, due to the likelihood of leaks, spills, drips, bad filling and fueling practices, etc.
In fact, these are almost a textbook definition of a REC, the "likely presence" of hazardous substances or petroleum products!
Many a gas station, service station, repair shop, or maintenance shop had, or continues to have hydraulic vehicle lift systems.
In the old days, these often meant a hydraulic reservoir and hydraulic lines beneath the surface, which was often concrete surfaced. The lifts we can see, but the reservoir and the lines we can't. Same as the UST/AST piping; the "likely presence of hazardous substances or petroleum products".
In this instance, we'll identify a REC associated with these. Even if they've been sealed over in the past, it's still going to be a REC.
Floor Drains & Sumps
These were once very common, and believe it or not, they're still being installed today. Doesn't seem to make much sense to have a drain in the floor of a building where things like oil, chemicals, and other contaminants can easily be washed into. Sure, modern installations may go to an oil / water separator or something similar, but what about the chemicals going down these drains?
If a building houses hazardous substances and petroleum products and has floor drains, chances are pretty good we're going to identify a REC from these features. And like the hydraulic lifts, that includes if floor drains were sealed over or filled-in in the past, since we have no idea what was sealed over, covered up, where they went, or what drained down them.
Oil / Water Separator.
We see this very frequently; a facility operator dismisses the floor drains as being a potential issue since they "drain to an oil / water separator". Great, we've heard that a million times before. We'll usually ask some follow-up questions like:
Is it maintained?
Where does it go to? The soils outside the building? If not, where?
Has anyone ever checked on how it's working? Are there any records to review?
If it's to the soils outside, then you can bet we're thinking of hazardous substances and petroleum products, under conditions indicative of a release. So, another REC.
This is kind of an odd one. Whenever we do a Phase I ESA at a gas station, service station, vehicle repair shop, maintenance shop, or just about any type of industrial facility, we inspect the bathrooms and shop sinks. Facility people always think it's odd, like we're checking if the bathroom is clean or not. And yes, in a way we are.
See, if we notice an old sink in the shop, or old toilet or sink in the bathroom, and they're stained with chemicals or petroleum products, we'll start asking questions.
Most importantly, where do these sinks and toilets go to?
If they go to a septic system, then there's a pretty good chance (the "likely presence") of there being the same hazardous substances or petroleum products in the septic tanks, or having been dispersed into a septic field meaning potential soil and groundwater contamination. Back in the day, common practice with unwanted used petroleum or hazardous substances was to pour it out & get rid of it. Could have been in a hole at the back of the property or down the sink or toilet.
Depending on what we see, we may or may not call out a REC.
Chemical Storage or Disposal Areas
Areas used to store, handle, use, and dispose of chemicals, solvents, cleaners, oil filters, sorbent materials, you name it, we're going to be inspecting carefully.
If the place has NASA clean-room sterile quality conditions, maybe it won't lead to a REC. We've seen it a few times at facilities running an extremely clean ship, but it's unusual. Otherwise, these areas are almost certainly going to result in a REC.
Areas used for painting could potentially result in releases of hazardous substances over time. Another REC.
Equipment, often oil-filled, used for machining parts creating metallic residue, or past grinding of brake drums which could have contained asbestos, is going to result in the identification of a REC.
Can a Phase I ESA find other RECs at gas stations, service stations, or repair shops?
Anything and everything else that might be present on the site which could be identified as the presence or likely presence of hazardous substances or petroleum products is going to get called out as a REC.
Filled area? REC.
Stressed vegetation? REC.
Old equipment? REC.
The list goes on and on...
Final note on Phase I Environmental Site Assessments at gas stations, service stations, or repair shops.
So you can clearly see that it's not going to be "just a UST" that we'll be looking for when we do a Phase I ESA at a gas station, service station, vehicle repair shop, or maintenance shop. You can almost guarantee that you're going to be looking at a list of numerous RECs.
Here are some additional articles you may find helpful to understand the Phase I process:
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