Comments
I would refrain from linking the 30 year Financial Assurance Requirements found in RCRA Subparts C or D to fate and transport of drycleaning solvents in the environment. That is a slippery slope. I know there are some pre 1982 PCE/TCE/DCE/VC plumes out there!Since groundwater is so shallow, you may want to consider a couple of push probe / temproary well point locations in the inferred down-gradient location of the shop area. You might just limit your analytical in the soil to TPH, running expanded tests (PCBs and BTEX+N) where TPH is detected. Target the soil sample for the base of the piston if you know that depth, otherwise fall back to field screening or the soil/water interface. The groundwater samples could get the full VOC 8260 list along with TPH, with possible expanded testing for PAHs and PCBS (and metals?) if you detect TPH.
It is not black and white, and so just as silly in my opinion to attempt to define a minimum length of time after which one would recommend a Phase II or a Baseline Investigation as related to a UST. One might be less concerned about a UST installed and monitored to current standards that is well above seasonal high water table, than the same UST that meets the same standards but is below the seasonal high water. Just one example of the various nuances. If not identified as a REC, and we are working for a buyer, it would often make sense to at least collect some baseline data around the tank area before the purchase occurs. It has not typically been an issue I have had to overanalyze since a vast majority of Site's I have worked on in the last 15 years have had older tanks in areas of shallow groundwater.
I agree with many of the comments above - it is typically a REC.
Yes, a REC.
Assuming no or inadequate sampling or documentation of sampling as part of the decommissioning, then this situation would be a REC.
I agree - a solvent UST with no sampling sufficient to show no release has occurred would be a REC.
I agree with everyone else - looks like a sewer clean-out. Having information / plans indicating that there is a sewer at this location would be helpful.
We often use professional judgement with this regard in cases where turbidity is an obvious issue (e.g. sample collected from temporary well point).
You asked for regulatory cites,so in Oregon, and with regard to Leaking UST sites:
OAR 340-122-0218(c) Sampling and Analysis: "Groundwater samples collected for the purpose of testing for lead must be filtered immediately upon collection using a 0.45 micron filter and analyzed for dissolved lead".
When sampling from a well (and for non LUST Sites), we will use low flow purging and sampling to reduce sampling-induced turbidity to a minimum.
Actually, you should set the intake within the upper portion of the screened interval, otherwise you are purging stagnant water above the well screen. Low flow purging and sampling is meant to avoid that.