What It Takes to Obtain a “No Further Action” Letter

For many contaminated properties, a “No Further Action” letter signifies years of continuous remediation efforts, as was the case for EnSafe’s diligent remedial efforts at a former automotive parts distribution facility since 2007. EnSafe earned a “No Further Action” letter on behalf of our client, Abston and Abston Realty, from the Tennessee Department of Environment and Conservation (TDEC) Division of Underground Storage Tanks (DUST) in 2021 with the help of technology.

Former Parts Inc. was a parts distribution firm that had single-walled steel diesel underground Storage Tanks (USTs) and private fueling stations for their trucking fleet operations. The USTs leaked over time, releasing an indeterminant amount of gas and diesel into the ground. EnSafe discovered the leaks and contamination from environmental investigations during onsite work. As these were regulated and registered tanks with TDEC Division of Underground Storage Tanks (DUST), the UST operators were mandated to perform a cleanup action at the site.

EnSafe initiated work on the site in 2007, when we performed a Phase I and Phase II environmental site assessment. In 2008, EnSafe designed the wellfield configuration and, as a licensed Corrective Action Contractor (CAC) for TDEC DUST, installed a 40Hp dual-phase extraction system, which performed soil vapor extraction and groundwater extraction. After eight years of continuous operations, EnSafe installed a free product treatment system to further reduce subsurface free product at the site. At the time, this was only the second site in the state that utilized the free-product system technology.

Since EnSafe began operations, the free product thicknesses at the site reduced from approximately 14 feet to less than an inch. Throughout the operations, maintenance, and monitoring (OMM) lifecycle, we performed groundwater and soil sampling at the site as well as timely alarm response, and we assisted the client with operations and innovative troubleshooting.

True to our commitment to client satisfaction, EnSafe has a proven track record of submitting quality monitoring reports to TDEC DUST. The client continued to use EnSafe to perform remediation efforts at the site until EnSafe obtained a “No Further Action” letter for the site, and our client was extremely satisfied with the remedial progress and our overall work.

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Posted in Case Studies, Insights/Innovation.