Some projects stay relevant long after construction wraps – especially when they highlight smart decision-making under pressure. This is especially true for challenges involving what is designated as a Potential Petroleum Contaminated Area, where careful planning makes all the difference.

In a Fall 2020 industry feature, a City of Houston construction project was recognized for successfully tackling unforeseen environmental conditions involving Potential Petroleum Contaminated Areas (PPCAs). Looking back, this project remains a strong example of how experienced environmental project management can protect schedules, control costs, and maintain regulatory compliance.

CRG Texas Environmental Services was proud to support the City throughout this effort regarding the site’s potential for petroleum contaminated area findings.

A Look Back at the Project

The site, a former car wash facility, had completed both a Phase I and Phase II Environmental Site Assessment prior to construction. The Phase II ESA identified two PPCAs: these were classified as Potential Petroleum Contaminated Area locations on the site.

• Area A: Shallow impacts associated with semi-volatile organic compounds (SVOCs)
• Area B: Shallow impacts associated with volatile organic compounds (VOCs)

Per Texas Commission on Environmental Quality (TCEQ) guidance and City of Houston specifications, these areas required excavation, screening, sampling, laboratory analysis, and proper soil management before construction could continue. In fact, handling any Potential Petroleum Contaminated Area demands strict protocol.

The Challenge at the Time

As construction moved forward, several unforeseen conditions were encountered: most notably, those related to petroleum-contaminated area risk.

• Limited on-site space for soil stockpiling
• Discovery of unregistered “ghost” underground petroleum storage tanks (USTs)
• The need for continuous air monitoring to protect workers and the public
• A fixed environmental budget paired with an active construction schedule

Approximately $450,000 had been allocated for environmental planning, monitoring, sampling, waste profiling, removal, and reporting. The challenge was finding a compliant solution that would not slow construction or inflate costs for any potential petroleum contaminated area encountered on site.

CRG Texas’ Approach

Working alongside the City Project Manager and construction team, CRG Texas reviewed alternative remediation and soil management strategies and proposed an alternate PPCA excavation and screening method. This tailored method was specifically designed for sites classified as a Potential Petroleum Contaminated Area.

Instead of traditional post-excavation sampling, the approach focused on:

• Grid-based, in-situ soil screening prior to removal
• Headspace screening using a photoionization detector (PID)
• Screening every 20 cubic yards of soil
• Segregation of soil into Type I and Type II categories
• Composite laboratory sampling tied directly to excavation volumes
• Detailed daily documentation to support waste profiling and reporting

This method allowed potential impacts to be identified early and streamlined excavation, segregation, and disposal activities for each Potential Petroleum Contaminated Area.

Results That Still Matter

Daily coordination between the City, CRG Texas, and the construction team ensured that excavation activities and laboratory results were reviewed in real time, yielding significant benefits for each designated potential petroleum contaminated area.

The results showed that soils in both PPCA areas did not contain SVOCs or VOCs at levels requiring special disposal. As a result:

• Excavated soil was classified as Type II
• Suitable material was reused on-site for backfilling
• Remaining soil was disposed of appropriately
• Environmental costs associated with PPCA handling were significantly reduced
• Construction was completed within the contract timeframe, finishing just 2% above the original construction cost

The facility successfully opened in July 2019, meeting the City’s operational goals without environmental delays.

Services Provided by CRG Texas

During this project, CRG Texas provided a full range of services often required while dealing with potential petroleum contaminated area sites:

• PPCA construction worker exposure air monitoring
• Monitoring of excavations, breathing zones, and fugitive emissions
• Soil and water sampling with laboratory analysis
• Impacted soil screening using PID technology
• Waste profiling, loading, transportation, and disposal coordination
• Removal of unregistered “ghost” petroleum storage tanks
• Sampling, laboratory analysis, and TCEQ reporting and closure documentation
• Environmental support during active construction

Why This Project Still Stands Out

Looking back, this project continues to reflect what CRG Texas does best: adapting to real-world site conditions, especially working in a Potential Petroleum Contaminated Area, while protecting clients from unnecessary delays and costs.

Whether working with government agencies or private developers, CRG Texas brings decades of experience managing PPCAs, petroleum-impacted sites, and complex construction environments across Texas.

Looking Ahead

While this project dates back several years, the lessons remain the same: early coordination, practical field strategies, and experienced environmental oversight make all the difference when conditions change, particularly in any potential petroleum contaminated area scenario.

If you’re facing PPCA concerns or petroleum-related challenges on an active site, our team is ready to help.