ATTACHMENT 10

 

MEMORANDUM

 

TO:                  W. Calvin Horton, Town Manager

 

FROM:            Bruce Heflin, Public Works Director

 

SUBJECT:       Replacement of the Public Works Underground Fuel Storage Tanks

 

DATE:             August  20, 2002

 

 

1. Federal Regulations required that all underground fuel storage tanks, without automatic leak detection, corrosion protection and spill/overfill prevention devices, be upgraded or replaced not later than December 1998.

 

2. The Town elected to satisfy this requirement by replacing three existing steel UST’s with two new fiberglass tanks.  Work on this project began in March of 1998 and was completed by the end of April 1998.

 

3. Our Environmental Engineering Consultant for this project, East Coast Environmental, submitted the following reports in conjunction with this work:

 

1. 4-hour Release and UST Leak Reporting Form dated March 24, 1998.  This document reported a small amount of petroleum contamination in the soil above the old tanks.  This was believed to be due to a leaking vent-line fitting on the top of one of the tanks that was repaired some time during the early 1980’s.

 

2. GW/UST-2 Site Investigation Report For Permanent Closure or Change-in-Service of UST dated April 16, 1998.

 

3. Report for Permanent Closure and Change in Service of UST System dated April 16, 1998.  This report noted that, upon removal of the existing steel tanks, they were inspected and found “to be in very good condition, with only minor pitting and structural degradation noted.”

 

4. The contaminated soil from the excavation of these tanks was stockpiled on the Public Works back lot pending resolution of questions regarding the best way to dispose of this soil.  It was decided that we would land-farm the soil and allow time for the petroleum contamination to dissipate.  The soil was tested periodically; however, after several years and several re-tests, contamination levels remained too high to keep the soil on site or to dispose of it at the Orange County Landfill.  During July 2002, we entered into a contract with Soilworks, a company licensed to accept and dispose of petroleum-contaminated soil, and we moved all of the soil to their facility.  The cost of disposal was approximately $8,600 for 860 tons.  About 100 truck loads of the material was hauled by Public Works dump trucks to a site located between Clayton and Wilson.  A soil manifest was then sent to DENR, which closed out the soil disposal requirements of this project.

 

5. NCDENR letter of January 21, 2001, notified the Town that we were required to submit a Limited Site Assessment on our UST facilities at Public Works.  This process includes the requirement to install one monitoring well at the site.   This letter was addressed to Mr. Paul Harvel, Fleet Manager who was ill at the time and subsequently died on February 14, 2001.  There is no record of this letter in our files and no action was taken on the letter.  The letter may have been inadvertently discarded when Mr. Harvel’s office was cleaned out after his death.

 

6. NCDENR letter of May 13, 2002, was a re-notification letter containing substantially the same information as was provided in their letter of January 21, 2001.  This letter allows us 120 days to respond by submitting the required Limited Site Assessment.

 

7. P.O. Number 707, in the amount of $6,547 was issued to East Coat Environmental on August 19, 2002, for installation of one monitoring well and preparation of the required Limited Site Assessment.