Leaking Underground Storage Tank Incident Closure
A gasoline release was reported at a national convenience store chain’s facility in Toulon, Illinois, during a systems upgrade in 2001. Soil and groundwater investigations were conducted, with site investigation and corrective action reports submitted to the Illinois Environmental Protection Agency (IEPA) by various consulting firms over the course of 20 years. Soil and groundwater contamination was identified both on-site and at off-site properties that historically operated as gasoline stations.
Shortly after AKT Peerless began oversight of the project, AKT Peerless submitted a Corrective Action Completion Report (CACR) to the IEPA in March 2022, requesting a No Further Remediation (NFR) Letter. As part of the CACR, AKT Peerless incorporated Tiered Approach to Corrective Action Objectives (TACO) Tier 2 site-specific remediation objective calculations to mitigate residual soil contamination, and limit institutional controls to easily-managed passive controls (on-site groundwater use prohibition, future construction controls, and land use restrictions). Our team also provided information proving that impacted groundwater was migrating onto the site from an un-remediated LUST incident at the neighboring property to the west.
The IEPA acknowledged that AKT Peerless’ client was not responsible for remediating the observed groundwater impacts and issued the NFR Letter one month later in April 2022.