The UST Removal and Closure Process
Regulated underground storage tanks (USTs) are required to be decommissioned if they are out of service for more than one year. USTs that are discovered during site redevelopment should also be promptly removed to eliminate the owner's liability for potential contamination. Envirologic has developed a full-service UST management program that is designed to help clients address the many aspects of compliance involved with UST closure. A step-by-step discussion of how Envirologic conducts UST removal and closure is included below.
- The Michigan Department of Licensing and Regulatory Affairs (LARA) Storage Tank Division requires the registration of USTs that contain regulated substances. In most instances, heating oil and small farm tanks are not included in this requirement and thus do not require registration. Envirologic's first step when a UST is identified is to prepare and submit a tank registration form to LARA. If possible, it is recommended that the tank is registered by the previous owner or party responsible for the tank. Envirologic also prepares and submits a 30-day UST Removal Notification to LARA and communicates with the local UST inspector regarding commencement of site activities.
- Envirologic may perform an initial assessment before tank removal to determine the contents and size of the UST. In many instances, however, data from a records review can provide this information instead. Where no useful information is available, a ground-penetrating radar (GPR) survey may be utilized to determine whether there are additional unknown USTs on site.
- Three days prior to the site activities, Envirologic notifies the Miss Dig network to identify any underground utilities that may be encountered during the removal. Envirologic also attempts to identify personnel who may have information regarding private services that may be present, such as septic piping/tanks, exterior lighting, sprinkler systems, etc.
- Initial site activities include removal of soil overburden above the tank, being careful to minimize disturbance of any piping, then pumping the contents of the UST and any piping above the tank. Once empty of liquid, the tank is typically opened and washed in place. Any liquid or sludges from the tank are properly disposed at a licensed facility. Once clean, the tank is extracted, decommissioned (i.e., cut or otherwise rendered unusable), and transported to a recycling facility. If the UST is located under a building or other permanent structure and its removal would cause damage to that structure, then it can be closed in place (i.e., cleaned and completely filled with a flowable material).
Image 1-Pumping tank contents before removal. Image 2-Extraction of clean and empty UST.
- Envirologic provides environmental oversight during the UST removal activities and conducts a UST Site Assessment as required by Michigan's UST regulations. A photoionization detector (PID) is utilized to scan soils from the base and sidewalls of the tank vault for evidence of a release. Visible fuel staining and/or odors would also be indicative that a release occurred. If a release is evident based on the PID responses, staining, or odors, then a suspected or confirmed release is reported to LARA within 24 hours of discovery.
- Following removal of the UST, regulations require that a soil sample be collected from the base of the UST vault beneath the fill port and that an additional soil sample be collected from the opposite end of the tank. A groundwater sample is collected if water is present. Envirologic submits the samples for laboratory analysis of the required parameters based on the tank's contents. Upon receipt of the analytical data, a confirmed release must be reported to LARA if any of the analyzed parameters are detected in the site assessment soil or groundwater samples.
- If a release is discovered, the owner/operator of the leaking underground storage tank (LUST) must complete corrective actions under Part 213 of the Natural Resources and Environmental Protection Act (NREPA). Funding is available under Michigan's Underground Storage Tank Corrective Action (MUSTA) Fund to complete cleanup activities. Refer to Envirologic's previous blog post on Using MUSTA Funds for more information.
- Within 45 days of the UST removal, Envirologic prepares a UST Site Assessment Report to document the UST removal and the results of the associated sampling activities. A revised Registration Form is also prepared and submitted to the state in order to remove the tank from the active UST database.
Envirologic has over 30 years of experience satisfying Michigan's UST and LUST regulations and utilizing cleanup funds, and we have assisted numerous clients through the regulatory process and cleanup of UST release sites. If you have questions about Envirologic's UST management services or concerns about a UST on your site, please contact our Project Manager Paul French. Paul has over 36 years of experience in the environmental consulting industry. He can be reached by phone at (800) 272-7802 or by email.