UST, LUST & CLOSURE ASSESSMENTS

LUST Final Assessment Reports (FARS)

If LUST closure is not achieved by the 90 day IAR timeframe, Part 213 requires that final assessment delineation activities be implemented. The QUSTC is not to wait for approval from the MDEQ (since the MDEQ does not review or audit IARs). Final assessment activities consist of two main components. The first component is the FAR delineation phase while the second component includes completion of a feasibility analysis and depending on the outcome, the development of a Corrective Action Plan (CAP).

The FAR delineation component is designed to effectively delineate the vertical and horizontal extent of the adsorbed, dissolved and, if present, phase separated hydrocarbon contaminant plumes. Once the plumes are fully defined, the QUSTC is required to evaluate which corrective action technologies apply to the site and once the most cost effective technology is determined, the QUSTC is required to design a CAP and include the feasibility analysis and the CAP in the Final Assessment Report.

The FAR, according to the statute, is due within 365 days of the discovery of the release. However, due to the extent of impact at many LUST sites and/or financial hardships, over 50% of all FARs are submitted well beyond the 365 day timeframe.

For further information regarding LUST FARs please contact Jerome Meyer at (800) 533-7474 and/or jmeyer@ies-environmental.com or James Springstead at (800) 553-7474 and/or jsprings@ies-environmental.com.