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In 1988, Federal and State Underground Storage Tank Regulations were established to govern owners and operators of underground storage tank (UST) systems. These regulations specify system component operations, performance standards, and monitoring requirements to minimize the likelihood of releases from UST systems. The UST system requirements were phased in over a ten-year period, based on the age of the UST system. Part 211 of Michigan's Natural Resources and Environmental Protection Act 451 of 1994, as amended (NREPA, PA 451), outlines the requirements for owners and operators of UST systems. In addition, those UST systems not covered by Part 211 must comply with the Storage and Handling of Flammable and Combustible Liquids Act 207 of 1941, as amended (FL/CL).

The Michigan Department of Environmental Quality (MDEQ) Waste and Hazardous Materials Division (WHMD) staff reviews applications for new UST systems or existing system modifications and conducts regular site inspections of active UST systems. These inspections are used to monitor the operations, check on the proper use of equipment, check record-keeping information, and ensure compliance with the UST regulations. Routine checks by the owner and/or operator are also required to prevent and detect releases from the UST systems.

Many UST system owners and/or operators, as well as prospective owners, have requested that R&W conduct evaluations of UST systems to determine the type and condition of equipment currently in operation at sites. These evaluations are often similar to the MDEQ inspections described above. This information is then used by owners and operators to make sound management decisions about the current conditions of the UST system and whether upgrades are necessary. R&W has also assisted numerous owners and operators with the design, contracting, and construction observation of new and upgraded UST system installations.

Leaking Underground Storage Tanks

If a release from a regulated UST system is detected, the owner and/or operator is required to report the release to the MDEQ-WHMD within 24 hours of detection. The release information and regulatory oversight is then transmitted to the MDEQ Remediation and Redevelopment Division (RRD). The owner and/or operator of the leaking underground storage tank (LUST) system is then required to comply with Part 213 of NREPA. The MDEQ-RRD is responsible for conducting periodic audits of work completed under the Part 213 program; however, the owner and/or operator is responsible for ensuring the completion of the work. The LUST program requires that owners and/or operators engage a Qualified Underground Storage Tank Consultant (QUSTC) and Certified Underground Storage Tank Professional (CUSTP) to conduct the necessary investigation of the release and, if necessary, remediation of the release.

R&W has been identified by the MDEQ as a QUSTC and employs CUSTPs to conduct investigations and remediation activities necessary to comply with the LUST program. These investigation services can include the physical characterization of soil and/or groundwater matrices, collection of soil and/or groundwater samples, proper analytical testing of collected samples, data evaluation, and reporting in accordance with the LUST program. The data evaluation is conducted using the Risk-Based Corrective Action (RBCA) method in ASTM International Standard Practice E 1739-95. Many clients select R&W to conduct the required investigations of LUST sites. If remediation is necessary, R&W assists the owner and/or operator with design and implementation of any remedial actions or remedies necessary for proper closure of the LUST site in accordance with appropriate regulations.

Aboveground Storage Tanks

Aboveground storage tank (AST) systems are used to provide storage for a variety of products including hazardous chemicals, petroleum products, propane, liquid petroleum gas, heating oil, and compressed natural gas. In Michigan these AST systems are regulated by the Storage and Handling of Flammable and Combustible Liquids Act 207 of 1941 (FL/CL), as amended. In many cases these regulations may dictate or require certain aspects of plan review and certification before installation, inspection and certification fees, changes in ownership, cessation of use the ASTs, changes in the content of the ASTs, and proper closure requirements. R&W has provided engineering services to numerous clients for the design, permitting, construction contracting, and construction observations of AST systems.

The MDEQ-WHMD regulates the AST program within the State of Michigan. Further information regarding the AST program can be obtained from the AST pamphlet provided by the MDEQ-WHMD.

Home Heating Oil Tanks

Home heating oil is typically stored in either an AST or UST system. When heating oil is no longer used on a property, the associated storage tank must be "taken out of service and properly closed" within one year. This means removal of excess heating oil, proper cleaning of the tank to remove any residue, and proper off-site disposal of the tank system. If the heating oil was stored in a UST system, the tank is either removed from the ground or filled with an inert material (e.g., flowable fill) if it cannot be safely removed from the ground.

Further information regarding heating oil tanks has been provided by the MDEQ Regulatory Guide to Home Heating Oil Tanks. R&W routinely assists home owners and commercial operations with the proper closure of heating oil tanks.

Please feel free to contact either Bill Bosze or Mark Westra for more information.

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