The goals laid out by the SWRCB in creating the Low Threat Closure Policy (LTCP) for underground storage tank cleanups were stated to be:

“The purpose of this policy is the establishment of low-threat petroleum site closure criteria. The policy is consistent with existing statutes, regulations, State Board precedential decisions and resolutions, and is intended to provide clear direction to responsible parties, their service providers, and regulatory agencies. The policy seeks to increase UST cleanup process efficiency. A benefit of improved efficiency is the preservation of limited resources for mitigation of releases posing a greater threat to human and environmental health.”
– Excerpt from the Draft Low-Threat UST Closure Policy dated July 14, 2011, pp. 1-2.

We are collecting information;  we have set up surveys (see pull down menu) to track the impact of the LTCP:

  • Consequences of the LTCP observed by local regulatory agencies, including the efficiency in implementation, and their initial observations;
  • Potential cumulative impact, both short term and long term, of leaving elevated concentrations of contaminants in soil and/or groundwater;
  • Legal perspectives on the effect of the LTCP on property owners, potential property purchasers and lending agencies.
Watch this space in the coming years as the policy’s implementation affects the California environmental regulatory world and as additional documents are produced and perspectives emerge.

Who Cares About This Issue?

Regulators will need to interpret the new policy.
Consultants will have to advise others and implement the new rules.
Property Owners or Prospective Property OwnersAdjacent Property OwnersPlanners, and Water Purveyors will need more resources to satisfy local regulatory cleanup objectives.

Please use the ‘Contact Us’ pull down menu to send information on sites which are good examples of LTCP closures or examples of sites which pose conflicts to the LTCP.  Information on sites which are good examples will be posted.